Privacy Policy

Last Updated: April 2024

Introduction

Unacast, Inc. (“Unacast,” “we,” “us,” or “our”) values individuals’ (“you” or “your”) privacy. In this Privacy Policy (“Policy”), we describe how we and our corporate affiliates may collect use, store, and disclose your information as it relates to:

  • Our data services – these are the data products and services that we provide to our Customers (the “Data Services”); and
  • This website, www.unacast.com (the “Website” or “Site”).

Our customers (“Customers”) are entities that use our Data Services.

Our partners (“Partners”) are companies that collect information from individuals, including, their mobile device’s location information, and provide that information to us in different data sets so that we can assist our Customers.

By visiting the Website, you agree that your information will be handled as described in this Policy. Your use of this Site is subject to this Policy.

Please note that this Policy does not cover our Customer’s use of the information we provide to them. Our Customers may associate the information we provide with additional information they have from other sources and may use this combined information for a variety of purposes, such as, targeted advertising, consumer insights, foot traffic analysis, fraud detection, law enforcement, and national security.

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, please refer to the EEA, U.K., & Switzerland Privacy notice here.

Who We Are

Unacast is the leading provider of mobility analytics and real-world location intelligence. Our technology verifies mobile consumer attendance at millions of places, points-of-interest, and local events, providing unprecedented insight into consumer activities and interests. We provide our Customers with location-based data services and analytics services based on inferred interests and matching of Location Data (defined below) against place and event data. Our Customers rely on our Data Services to power mobile advertising and marketing campaigns and use our data services to more deeply understand their customers, acquire competitive intelligence, to conduct law enforcement activities and enhance national security, and to provide and improve the services they offer to their own customers.

Description of Services

Unacast collects and processes various types of information from mobile devices which we receive from our third-party partners. These third-party partners are owners of mobile applications (“App(s)”) or data aggregators who primarily receive data from software development kits (“SDKs”) in Apps (SDKs allow developers to embed certain third-party functionality into their own software applications). They may also receive data from (i) WiFi routers, and/or (ii) Bluetooth beacons (these are devices placed in stores that emit Bluetooth signals and collect ID information of smartphones in their vicinity to provide related advertisements to those smartphones).

The data we receive from our Partners includes location data in the form of latitude/longitude (“Location Data”), which is associated with a mobile advertising ID, such as Apple’s Identifier for Advertisers ( IDFA) or a Google Advertising ID (Advertising ID/Ad ID). Each mobile advertising ID allows us to identify each unique mobile device and is used by advertisers and marketers to display ads to your device. Using proprietary algorithms, Unacast cleanses, processes and merges the Location Data that we receive from all sources to create a portfolio of derivative Location Data products and tools. We also may receive other information from our third-party partners about a mobile device, such as IP address and Device User Agent Data (as defined below).

Additionally, we create virtual boundaries, known as geo-fences, around locations of interest, such as shopping centers, restaurants, and events, like professional sports matches, concerts, and county fairs. We then combine the Location Data we receive with our geo-fences, and other information that we create and collect about physical locations, such as venue, hours of operation, and events, and use such combined data to make inferences about the types of activities or events users of such mobile devices enjoy or spend time doing. We use the Location Data and the resulting inferences to provide our Data Services to our customers.

Our Data Practices

  1. Information We Collect About You
  2. How We Use Your Information
  3. How We Share Your Information
  4. Supplementary Information for Individuals Residing In Select U.S. States
  5. Our Use of Cookies and Other Tracking Mechanisms
  6. Third-Party Links
  7. Security of Your Information
  8. Privacy Choices
  9. Retention
  10. Children

1. Information We Collect About You

We collect the following information when you browse or submit an inquiry on our Website, contact us to request information about our products and services, or apply for a job.

We collect the following information about you from our Partners and use it to provide our Data Services:

Information Category

Description of Information Collected

Identifiers

IP address, and the following information if you choose to provide it to us: name, email address, phone number; job and company information, and state.

Device Information

Your browser type and operating system, time zone setting and location, browser plug-in types and versions.

Internet or Network Activity

Web pages you view, links you click, the length of time you visit our Site, and the webpage that led you to our Site.

Communications Preferences

Your preferences in receiving marketing from us and your communication preferences.

Professional or Employment Information

If you apply for a job, current or past job history or performance evaluations.

Location Data

Precise geolocation data, including latitude-longitude coordinates obtained from Apps via requests to the mobile device operating system which utilizes various mechanisms to derive Location Data, including GPS tools, cell tower triangulation, WiFi data, or other techniques. We do not collect your precise geolocation data in real-time. Neither Uncast, nor its third-party data partners determine whether Location Data is received from GPS signals, cell tower triangulation, WiFi data, or by other techniques. The device operating system determines which signal is most readily available to the device and returns the Location Data to the corresponding App provider.

Identifiers

IP address; mobile advertiser ID ("MAID"); hashed e-mail

Internet or Network Activity

Timestamp, list of Apps from which location signals were received.

Device User Agent Data

Device type; browser family; browser version; operating system; version of operating system; device model number, carrier data

Demographic Data

Age, gender, generational suffix, marital status, parental status, number of children, educational level, yearly income.

"Bidstream Data"

Uncast DOES NOT collect mobile advertising bidstream data to support our Data Services. We likewise ask our third-party partners to refrain from supplying data sourced from the mobile advertising bidstream.

2. How We Use Your Information

Unacast uses information we collect through our Website for the following purposes:

  • Providing and Improving Our Services. We use your information to provide, improve, and personalize our services to you.
  • Marketing and Communications. We use your information to communicate with you about our services, respond to your inquiries, administer surveys and questionnaires, to provide customer service, and for marketing and promotional purposes. For example, we may use your information to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you. We also may use the information that we learn about you to assist us in advertising our services.
  • Research and Analytics. To better understand how you access and use our Website, and for other research and analytical purposes.
  • Protecting Rights and Interests. To protect the safety, rights, property, or security of Unacast, our services, any third-party or Partner, or the general public; to detect, prevent, or otherwise address fraud, security, or technical issues; to prevent or stop activity that Unacast, in its sole discretion, may consider to be, or pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; to conduct audits; and to enforce this Policy.
  • Legal Compliance. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.

Unacast uses the information we receive from our Partners to provide Data Services to our Customers. We do not use information collected through our Website to provide our Data Services. Using the information we receive from our Partners, we create a portfolio of your device’s Location Data records that are associated with your mobile advertising identification number. We also create virtual boundaries called “geofences” around locations of interest, such as shopping centers, restaurants, and events. We take your device’s Location Data and combine it with these geofences, as well as other information noted above, to determine the venues and events you attended and to infer your preferences. As part of our Data Services, we also:

  • Categorize device users into interest segments called “personas” and “audiences.” You can view a list of our audiences at the following link: https://www.unacast.com/products/advertising-audiences .
  • Track key performance indicators throughout the length of an advertising campaign and determine whether a MAID that was served an ad visited a particular store or location;
  • Create insights and trends about consumer behaviors, including foot traffic at and surrounding a particular location and predicting future behavior; and
  • Create competitive consumer intelligence for our Customers, such as identifying new customers that may be interested in their offerings, targeting and enhancing marketing and advertising capabilities for our Customers.

We do not use the information we collect about you to determine employment eligibility, credit eligibility, insurance eligibility, underwriting, or for pricing purposes.

3. How We Share Your Information

We may share your information as follows:

  • Affiliates: We may disclose your information to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your information will be subject to this Policy.
  • Service Providers: We may disclose the information we collect to third-party vendors, service providers, and contractors or agents, who perform functions on our behalf.
  • Customers: When we provide our Data Services, we share with our Customers your information, including your device’s location information, mobile advertising identifier, venues and events you attended, interest segments, and device information. Our Customers may use this information for purposes such as advertising attribution analysis and services; marketing and personalized advertising; market research, including consumer research; business intelligence, such as consumer insights, foot traffic and analysis; providing fraud detection analytics and services; movement intelligence analytics; providing security services; law enforcement and national security; and public-health. In some circumstances, our Customers may also resell your information to other third parties for similar purposes.
  • Data Management Platforms and Third-Party Ad Networks. We disclose your information, including your mobile advertising identifier and interest segments, to third-party ad networks to provide you with targeted advertisements, as more specifically described in the Third-Party Network Advertisers paragraph in the “Privacy Choices” section of this Policy. When you visit our Website, third-party advertising providers collect information about your visit to track your responses to ads we have placed on other websites, and to inform our understanding of how users navigate our Website
  • Analytics Providers. We may disclose information we collected through our Website to our analytics providers such as Google Analytics, to evaluate usage of our Site, and to help us improve our services, performance and user experiences. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
  • Aggregate and De-Identified Information. We may share information that has been aggregated and de-identified with third-parties for marketing, advertising, research, or similar purposes.
  • Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
  • To Protect Us and Others. We may share your information where we believe it is necessary to investigate, prevent, or act regarding illegal activities, suspected fraud, potential threats to the safety of any person, violations of this Policy, or as evidence in litigation in which Unacast is involved.
  • In Response to Legal Process. We also may disclose the information we collect if we believe that such action is necessary to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
  • With Your Consent. We may disclose the information we collect from you with your consent.

4. Supplementary Information for Individuals Residing In Select U.S. States

Under various U.S. State privacy laws, you may have certain additional rights that pertain to your data privacy. These additional privacy laws require Uncast to provide individuals with certain information about the processing of their “personal information” and the rights that are available to them under such laws.

Personal Information

Generally, “personal information” is defined as “any information that directly or indirectly identifies, relates to, describes, or can be associated with or reasonably linked to “an individual or household”, including, name, address, mobile device identifiers, precise location data, IP and cookie identifiers, inferences, and biometric data.

The following table discloses what categories of “personal information” (as defined by various U.S. state privacy laws) we have collected from or about individuals within the last twelve (12) months:

"Personal Information" Category

"Personal Information" Examples

Personal Information Collected by Unacast From Website

Personal Information Collected by Uncast From Data Partners

Identifiers

Name, address, device identifier, Internet Protocol (IP) address, cookies, web beacons, account name, social security number, passport number, or other similar identifiers

(i) Device identifier and IP address, and (ii) name, phone number, and email address, but only to the extent you have provided us with this information when you submit a comment or request through our Website.

Device identifier, IP address

Customer Records

Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Name, phone number

No

Internet or Network Activity

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement

Timestamp and lists of mobile applications from which location signals were received.

Geolocation Data

Physical location or movements

No

Yes

Inferences

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

No

No, but as part of its Data Services, Uncast does make certain inferences. Please refer to our Description of Services section of this Privacy Policy for more information.

Professional or Employment Information

Current or past job history or performance evaluations

Yes, to the extent you provide us with this information as part of an application for employment.

No

Protected Classification Characteristics under U.S. State Privacy Laws or Federal Law ("Demographic Data")

Race, color, national origin, religion, gender, age, or disability

No

Age and gender

Categories of Sources of Personal Information

We receive your personal information from the following categories of sources:

  • From you. Directly from you through your provision of the information to us directly on our Website or automatically from your use of our Website or as described further in this Privacy Policy;
  • Our customers. Our customers may directly provide us with your information for our performance of services to them; and
  • Third Parties and Partners. Our third-party data suppliers (data resellers) who either directly or indirectly collect your personal information and provide it to us for our provision of the Data Services, as described in this Privacy Policy.

Use of Personal Information

Please refer to the “How We Use Your Information” section of this Privacy Policy for information on how we use your personal information with respect to the Data Services and our Website.

Disclosing Personal Information for a Business Purpose

Business Purpose

We may share your personal information with affiliates and service providers for a business purpose, which different privacy laws generally define as the use of personal information for operational or other notified purposes. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

  • Identifiers;
  • Precise Geolocation Data;
  • Internet or Network Activity;
  • Demographic Data; and
  • Inferences
  • Mobile Device User Agent Data

The following are categories of third parties to whom we have disclosed your personal information for a business purpose:

  • Our affiliates; and
  • Service providers.

Sale of Personal Information

In the preceding twelve (12) months, we have sold the following categories of personal information in order to monetize our services:

  • Identifiers;
  • Precise Geolocation Data;
  • Internet or Network Activity;
  • Demographic Data; and
  • Inferences.
  • Mobile Device User Agent Data

Categories of parties to whom we have sold your personal information:

  • Our affiliates;
  • Vendors,
  • Third parties, which include our customers, partners, law enforcement, data management platforms, and third party ad networks.

Your Rights in Connection with Personal Information

Many U.S. State privacy laws grant you a number of rights (subject to certain exceptions) with respect to your personal information that companies may hold about you. Each of your rights is outlined in more detail below:

  • Right to Know & Right to Access. You have the right to request that we tell you:some text
    • the categories of personal information we collected, sold, or disclosed for a business purpose in the previous 12 months;
    • the categories of sources from which we collected such personal information;
    • the business or commercial purposes for collecting and selling such personal information; and
    • the categories of third parties to whom we sold or disclosed for a business
    • purpose such personal information and the specific categories of personal information sold or disclosed to each category of third party.
  • In addition, you have the right to request a copy of the specific pieces of personal information that we have collected from you in the 12 months preceding your request. If we are able to confirm your identity to the degree required by law and corresponding regulations, we will disclose to you a copy of the specific pieces of personal information about you that we have processed.
  • Please click here for more information on exercising your Right to Know/Access or click on the Right to Know link at the bottom of our home page.
  • Right to Delete. You have the right to ask us to delete or remove the personal information we have collected from you and retained. Upon our confirmation of your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies (for example, where your information helps us comply with a legal obligation, or detect or prevent security incidents, or as required to comply with applicable law).
  • Right to Opt-Out of Sale. Where we sell your personal information, you have a right to opt out of such sale and any further resale of your personal information. You can opt-out of the sale of your personal information here or by clicking on the “Opt-Out and Do Not Sell” link available on the home page, and on all other Unacast Website landing pages. If we receive any opt-out request either directly or through a third-party partner, we will cease selling your personal information, as “sale” is defined under U.S. State privacy laws.

How to Exercise your Rights

In order to exercise any of the rights described above, please contact us by either:

  • Calling us toll-free at 1-855-545-5623; or
  • emailing us at: privacy@unacast.com

We may need to request specific and/or additional information from you to help us confirm your identity and ensure your right to know, access or delete your personal information. Information on Unacast’s verification process can be found here. This is a security measure designed to prevent the disclosure of your personal information to a person who has no right to receive it.

We will only use this information to verify your identity or authority to make the request. An authorized agent submitting a request on behalf of a consumer must demonstrate that the consumer provided written permission, signed by the consumer authorizing the agent to act on the consumer’s behalf. For requests for information and deletion, Unacast may require that you verify your own identity directly with Unacast and directly confirm that you provided the authorized agent permission to submit the request.

We will deliver our written response by mail or electronically, at your option. We will not charge you a fee for access to your personal information (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, excessive, or manifestly unfounded, or we may refuse to comply with your request in these circumstances.

We will not be obligated to respond to more than 2 requests for data access/data portability in a 12-month period. Any responses will cover the 12-month period preceding your request.

If you have opted out of the sale of your personal information, you may change your mind and opt back in at any time by contacting privacy@unacast.com.

Shine the Light

California’s Shine the Light Law (Civil Code 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please refer to any of the contact methods in the Contact Information section below.

5. Our Use of Cookies and Other Tracking Mechanisms

We and our third-party service providers use cookies and other tracking mechanisms to track information about your use of our Site. We may combine this information with other information we collect from you (and our third-party service providers may do so on our behalf).

Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Third-Party Ad Network section.

Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.

  • Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site.
  • Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity, and to display advertising both on our Site and on third-party sites.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse certain areas of the Site, but some features may not function.

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third-party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

Our Site and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third- party websites.

7. Security of Your Information

We have implemented appropriate administrative, technical, and physical safeguards to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security.

8. Privacy Choices

Data Services Opt Out. If you would like to opt-out of our use of your device’s Location Data and other related data we use in our Data Services, you can (a) disable location services on your mobile device, or (b) complete the Opt-Out & Do Not Sell Form. Please note that your opt-out will be specific to the device for which you submit the opt-out request. This means that if you use multiple devices, you will need to opt out each device that you use. In addition, if you re-set your mobile advertising ID, you will need to opt out that device again.

Third Party Ad Network Opt Out. We may use third-party network advertisers to serve advertisements on third-party websites or other media (e.g., social networking platforms). This enables us and these third parties to target advertisements to you for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. We may provide these third-party advertisers with information about you.

Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members, of which we are one. Additionally, you may also go to the NAI’s Audience Matched Advertising Opt-Out Page for more information about opting out of digital advertising linked to hashed email addresses (“HEMs”).

Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites. Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective.

Email Marketing Opt Out. You may opt-out of receiving promotional communications from us by following the opt-out instructions contained in the e-mail. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails about recommendations or other information we think may interest you, we may still send you e-mails about your account or any services you have requested or received from us.

9. Retention

We retain your personal information for so long as retention is necessary to comply with our legal and contractual obligations, enforce our agreements, and enable us to investigate events and resolve disputes. We store Location Data, Internet or Network Activity, and Device User Agent Data, associated with a particular mobile advertising ID and used for our Data Services, for up to four (4) years, provided, we may retain such personal information for a longer period to the extent it is required for a legal or significant operational purpose, such as for compliance, record-keeping, auditing, safety and security, and error or bug prevention.

10. Children

Our Services are not designed for children under 16. If we discover that a child under 16 has provided us with personal information, we will delete such information from our systems.

NAI Membership

Unacast is a member of the Network Advertising Initiative (NAI) and we undergo annual reviews that we adhere to their Code of Conduct. If you wish to learn more about the NAI or about options available to you to opt out of receiving targeted advertising from other third party services that are also members of the NAI, please click here.

Data Broker

THE ENTITY MAINTAINING THIS WEBSITE QUALIFIES AS A DATA BROKER UNDER VARIOUS DATA BROKER LAWS. UNACAST IS A REGISTERED DATA BROKER. 

Contact Us

If you have any questions or would like to speak with us regarding changes to your personal information, please email us at privacy@gravyanalytics.com, call us at 703.840.8850, or write to us at:

Unacast
44679 Endicott Drive, Suite 300
Office 349
Ashburn, VA 20147

Changes to the Privacy Policy

This Policy is current as of the Effective Date set forth above. We will post any changes to this Policy on our Site. If we make any changes to this Policy that materially affect our practices with regard to the information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.

Looking beyond CCPA & GDPR to the future of privacy

We wholeheartedly believe that privacy is a concept to which every human that uses a connected device has a fundamental right — and it’s built into every part of our business.

At Unacast we are committed to protecting and respecting data privacy and see privacy as a key driver for the growth of location technologies. Our privacy program covers the flow of location data from the point of collection to our customers’ platforms. Through our partner terms and conditions as well as through reviews of their privacy practices by our designated privacy officers, we strive to ensure that all our partners who contribute location data to us collect, use, and disclose the location data in compliance with applicable privacy laws and industry privacy standards.

We insist, among other things, on:

  • Proper disclosures relating to the collection of location data
  • User opt-in consent for the collection of location data from mobile devices
  • Respecting mobile device users’ choices and device settings

Moreover, we also require that our customers process location data received from us in compliance with applicable privacy laws, industry standards, and their own privacy policies.

Finally, while we do not directly collect any location data, we are mindful about the privacy concerns that the users of mobile devices may have about location technologies. We describe our own privacy practices relating to the location data we receive from our partners in our Privacy Statement. If you are a visitor to our website, you can read about our privacy practices relating to the data we collect from our website in our Privacy Policy.

Privacy Statement

Last Updated: August 30, 2021

1. Introduction

Unacast, Inc. and our subsidiary Unacast AS of Norway (“Unacast, “we”, “us”) are committed to protecting and respecting privacy and the protection of information that may be used to identify you directly or indirectly (“Personal Data”). This Statement explains our approach with respect to data we receive from our partners, such as mobile application (“App”) developers and publishers, data aggregation services, and providers of location-supporting technologies (the “Partners”). The technologies utilized by the Partners interact with mobile devices in the physical world through Apps, GPS, mobile device Bluetooth connections, and Wi-Fi connections. In this Statement we also provide information on some of the methods available to individual users of mobile devices (“you” or “user”) to limit the collection of data from or about their mobile devices by the Partners.

2. How Does Unacast Obtain Data And What Data Do We Obtain?

Some of the data we receive from the Partners may constitute Personal Data under applicable laws.

The data provided by the Partners may include:

  • IDFA and/or advertising identifier (“Advertising ID”)
  • Location of the mobile device expressed as the latitude, altitude, and longitude of the mobile device and the derived identity of the location, such as a fast food restaurant
  • Mobile device operating system and operating system version
  • Mobile device make and model
  • The name and version of an App
  • Other metadata associated with the mobile device, such as network type and IP address
  • The category of the App that collected data (i.e. casual gaming, weather, social media)
  • GPS horizontal accuracy value
  • If the App was in active use or in the background when data was collected
  • The speed at which the device was traveling
  • If the device was being charged at the time of data collection
  • The direction that the device was traveling
  • If the device is connected to a WiFi or cellular network
  • WiFi SSID (network name) or BSSID (MAC address for the router)

Where required by law, such as in the European Economic Area, we process the data provided by the Partners based on your consent that you have provided to our Partners. Please be reminded that you have the right to withdraw your consent at any time.

3. What Do We Do With Partner-Provided Data And For What Purposes Is It Used?

We analyze and contextualize the data provided by the Partners for purposes of providing accurate location intelligence to our clients. This location intelligence can be used for advertising, audience segmentation, people-based movement analytics, improving business decision making by better understanding of customer movement patterns, assisting municipalities in urban planning by enhanced understanding of movement patterns, and similar purposes that utilize location as a tool. The data may also be used for the purpose of improving and analyzing the various services provided by us.

4. In What Ways Can I Control the Collection of Mobile Device Data?

Data Collected Through Apps

PRIVACY POLICIES

First, please familiarize yourself thoroughly with the privacy policy of any App you download on your mobile device, checking in particular what types of data the App collects from or about your device(s). Do not download an App if you do not feel comfortable with the data collection practices described in the applicable privacy policy. If you have already downloaded such an app, delete it.

DEVICE SETTINGS

All major mobile device operating systems enable the users of mobile devices to control the types of data collected in and through Apps.

iOS: Apple instructions on how to control iOS device location settings can be found here: https://support.apple.com/en-us/HT203033. Apple instructions on how to limit ad tracking on iOS devices can be found here: https://support.apple.com/en-us/HT202074. For other privacy-related settings on iOS, please go to Settings from your mobile device’s home screen, and select “Privacy.”

Android: Android instructions on how to control device location settings can be found here: https://support.google.com/nexus/answer/6179507?hl=en&ref_topic=6179522. Android instructions on how to limit ad tracking on Android devices can be found here: https://support.google.com/nexus/answer/3118621?hl=en.

Data Collected Via Bluetooth

All major mobile device operating systems enable the users of mobile devices to disable Bluetooth from functioning.

iOS: You can disable Bluetooth by going to “Settings” from your Device’s home screen; select “Bluetooth”; and turn Bluetooth off.

Android: You can disable Bluetooth by going to the Settings app, then “Wireless and networks,” where you can disable Bluetooth.

5. How Does Unacast Disclose the Partner-Provided Data to Third Parties?

We may disclose the data provided by the Partners to third parties such as advertising networks, advertising publishers, and advertisers, research companies, data brokers, financial institutions, data analytics platforms (collectively “Data Licensees”), in accordance with the terms of the agreements, and only for the purposes of performing such agreements, that we have in place with such third parties.

We may also disclose data provided by our Partners to:

  • Our service providers, such as data storage providers;
  • Public authorities, such as law enforcement, if we are legally required to do so or if we need to protect our rights or the rights of third parties; and
  • Our subsidiaries and affiliates; or a subsequent owner, co-owner or operator of our services and their advisors in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our stock and/or assets, or in connection with bankruptcy proceedings, or other corporate reorganization.
  • A list of Data Licensees, and a link to their privacy policies, can be found here.

6. How Do I Check Whether Unacast Has the Advertising ID of My Mobile Device and Can I Block It From Further Use by Unacast?

You can find your mobile device’s Advertising ID on iOS by use of apps like e.g. My Device ID, and on Android by going to Settings, then selecting “Ads”. You can opt out by filling in your Advertising ID in this opt-out form, and request the blocking of the Advertising ID from further use or disclosure by Unacast. If we have that Advertising ID, once we have blocked the Advertising ID, you will receive a confirmation email from us. Please bear in mind that the blocking of the Advertising ID by Unacast following your request to that effect will not have an impact on any uses or disclosures that have already taken place. If you choose to reset your mobile device’s Advertising ID, you will have to request blocking of the Advertising ID from further use or disclosure by Unacast once again. Please also bear in mind that any additional devices you may possess have other Advertising IDs. Finally, please be aware that the use of any of the measures enlisted in this Statement does not mean that no advertising will be directed at your mobile device.

7. Other Rights You Have

We take steps to help ensure that you are able to exercise your rights regarding Personal Data about you in accordance with applicable law. If you would like to access, erase, or object to, or restrict the processing of Personal Data we collect, please visit this site. We will promptly review all such requests in accordance with applicable laws. Depending on where you live, you may also have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Data about you. We encourage you to first reach out to us at privacy@unacast.com, so we have an opportunity to address your concerns directly before you do so.

8.  How Long Does Unacast Keep Data About Me?

As a matter of policy, Unacast retains data received from our Partners for purposes of advertising and audience segmentation for a period of six (6) months from the date that we first receive data. For other purposes, as described above in Section 3, we may retain data for five (5) years from the date that we first receive the data.

Finally, unless we are legally required to do otherwise, if you submit a request in accordance with the instructions set out in Section 6 above, we only retain that Advertising ID for purposes of blocking it from further use and disclosure by Unacast.

9. International Transfers of Personal Data

Some elements of our data products and services may be hosted on servers located in countries outside your own country. The laws applicable to the protection of Personal Data in such countries may be different from those applicable in your home country. In particular, if you are located within the European Union, please note that Personal Data received by us from Partners may be transferred outside the European Union (the “EU”)/ European Economic Area (the “EEA”). If we transfer personal data from the EEA to third countries, we utilize standard contractual clauses authorized by the Commission of the European Union (“CEU”), or other transfer mechanisms determined lawful by the CEU or EEA Member State supervisory authorities in connection with such transfers.

10. For California Residents

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of personal information by Unacast to third parties for the third parties’ direct marketing purposes. To make such a request, please send an email to privacy@unacast.com or write us:

Unacast, Inc.
PO Box 216 
Cos Cob 
152 E Putnam Ave 
Cos Cob, CT, 06807-9984

Furthermore, California residents have the following rights with respect to Personal Data we may have collected about them:

(i)      Requests to Know

You have the right to request that we disclose:

  • The categories of Personal Data we have collected about you;
  • The categories of Personal Data about you we have sold or disclosed for a business purpose;
  • The categories of sources from which we have collected Personal Data about you;
  • The business or commercial purposes for selling or collecting Personal Data about you;
  • The categories of Personal Data sold or shared about you, as well as the categories of third parties to whom the Personal Data was sold, by category of Personal Data for each party to whom Personal Data was sold; and
  • The specific pieces of Personal Data collected.

You may submit a request to know via this form. The delivery of our response may take place electronically or by mail. We are not required to respond to requests to know more than twice in a 12-month period.

(ii)      Requests to Delete

You have the right to request that we delete any Personal Data about you that we have collected. Upon receiving a verified request to delete Personal Data, we will do so unless otherwise authorized by law. You may submit a request to delete Personal Data via this form.

(iii)     Right to Opt Out of the Sale of Personal Data

You have a right to opt out of the sale of Personal Data. You may, at any time, direct us to not sell Personal Data about you to third parties.  If you exercise your right to opt out of the sale of Personal Data about you, we will not sell Personal Data about you. Any Personal Data collected in connection with your request to opt-out of the sale of Personal Data about you will be used only to facilitate that request. You may opt out of the sale of Personal Information about you here. You may also submit opt-out requests by emailing us at privacy@unacast.com.

(iv)     Authorized Agents

You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney pursuant to Probate Code sections 4000-4465 may submit a request on your behalf.

(v)     Methods for Submitting Consumer Requests and Our Response to Requests

You may submit a request for access and requests to delete Personal Data about you via this form.

Upon receipt of a request, we may ask you for additional information to verify your identity. Any additional information you provide will be used only to verify your identity and not for any other purpose.

We will acknowledge the receipt of your request within ten (10) days of receipt. Subject to our ability to verify your identity, we will respond to your request within 45 days of receipt. In order to protect your privacy and the security of Personal Information about you, we typically verify your request by requesting additional identifying information relating to you and/or you’re your mobile device.

With respect to requests for specific pieces of Personal Data, we have determined that there is a substantial safety and security risk to a person in disclosing the geolocation of a device to another person who (i) is not the actual user of a mobile device with which geolocation data is associated, but (ii) has an interest, whether lawful or unlawful, in gaining access to geolocation data associated with a device and the movement patterns of the actual user of the device.  Given this risk, and (i) since we do not seek to determine the actual identity of persons that use mobile devices for our business purposes; (ii) we do not collect identifiers such as names, addresses, cellular/mobile phone numbers; and (iii) because we do not wish to collect extensive additional Personal Data for verification purposes, we have concluded that we currently have no reasonable method to verify the identity of the person making the request for purposes of verifying requests for specific geolocation information to a reasonably high degree of certainty. Consequently, we do not provide specific geolocation in response to data subject/consumer requests at this time. We will re-evaluate this determination on a yearly basis.

(vi) Categories of Personal Data the We Have Sold in the Last 12 Months

We have sold the following categories of Personal Data during the last 12 months:

(A) Mobile device identifiers;

(B) Internet or other electronic network activity information, including information regarding your interaction with a mobile application, and

(C) Geolocation data.

(vii) The Right to Non-Discrimination

You have the right not to be discriminated against for the exercise of your California privacy rights described above.

For information about the number the number of requests to know we have received and complied with, requests to delete we have received and complied with, requests to opt-out we have received and complied with, and the median or mean number of days taken to respond to each group of requests, please see this link.

11. Children's Privacy

The data provided by our Partners does not include Personal Data relating to children younger than sixteen (16) years of age.

12. Changes to This Statement

From time to time we may change this Statement. You can tell when changes have been made to the Statement by referring to the “Last Updated” legend on top of this page. Please review this Statement regularly to ensure that you are aware of any changes.

13. Questions or Concerns?

Should you have any questions regarding this Statement or your privacy, please contact our Privacy Team at privacy@unacast.com. We seek to promptly resolve any questions or concerns you may have.

Privacy Policy


Last Updated: March 12, 2020

1. Introduction

Unacast, Inc. and our subsidiaries and affiliates (“Unacast, “we”, “us”) are committed to protecting and respecting your privacy. This Privacy Policy explains the policies adopted and used by us in order to protect your privacy as you visit and use our website located at www.unacast.com, and associated sub-domains such as our data portal (the “Portal”) available at console.unacast.com (collectively, the “Website”) and if you otherwise communicate with us, for example by requesting information related to our services. The Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be handled by us. In this Privacy Policy, the term “personal data” means information that relates to an identified or identifiable natural person.

We know that you are concerned about how we use and disclose personal data, and we are committed to complying with data protection and privacy laws that apply to us. This Privacy Policy tells you about the ways in which we protect your privacy and personal data we process about you in connection with the Website. We wish to remind you that this Privacy Policy applies to personal data that we process when you use the Website and if you otherwise communicate with us, for example by requesting information related to our products and services. It does not apply to any links to third parties’ websites and/or services, such as third-party applications, that you may encounter when you use the Website, or personal data processed in connection with our data products. If you wish to know about our practices relating to personal data processed in connection with our data products, please review our Privacy Statement. We encourage you to carefully familiarize yourself with privacy policies applicable to any websites and/or services operated by third parties. Please be aware that we are not responsible for the privacy practices of any third parties.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING THE WEBSITE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND BY ALL OF THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THESE TERMS, DO NOT ACCESS OR USE THE WEBSITE.

2. Information We May Collect From You

Data You Provide to Us

When you use the Website or otherwise communicate with us, we collect information that you provide to us directly. For example, we collect information in the following circumstances: when you sign up for a newsletter, when you register an account with the Portal, when you subscribe to our products and services, when you contact us via the Website; when you submit a job application, and when you otherwise communicate with us.

The information you provide to us directly may include, without limitation, the following information that may, alone or in combination with other data, constitute personal data:

  • Company name;
  • First name, Last name;
  • Phone number;
  • Website;
  • Email address;
  • Information included in your CV/resume;
  • Information available in your public LinkedIn profile; 
  • Information on your preference about joining our mailing list.

Other information: We may also collect any other information you may want to share with us, such as a record of your correspondence, if any, with us. To the extent there are any payment features on the Website, we use a third-party payment processor to process any payment information. 

Personal Data You Provide To Third Parties On Our Site

Please note that we use certain third party service providers on the Website to enhance your experience or deliver certain services. These providers may collect Personal Data in performing their services and/or functions on the Website. For example, we use the following third party service providers for the services identified:

  • Lever.com to collect Personal Data relating to open positions posted on our Site. To learn about the privacy practices of Lever, please review https://www.lever.co/privacy-policy

Data Collected Automatically

Certain information on our Website is collected automatically by means of various software tools. We have a legitimate interest in using such information to assist in log-in, systems administration purposes, information security and abuse prevention, to track user trends, and to analyze the effectiveness of the Website. Alone or in combination with other information, such automatically collected information may constitute personal data. We may also use third-party analytics tools (such as Google Analytics) that collect information about the use of the Website and visitor traffic. The information we may collect by automated means may include, without limitation:

  • Information about the devices you use to access the Website (such as the IP address and the type of the device, operating system, network connection, and web browser);
  • Dates, times, and duration of use of the Website (including whether you are a repeat or first-time visitor); and
  • Information on actions taken when using the Website (such as page views and website navigation patterns).

We use cookies to make interactions with the Website easy and meaningful. When you visit the Website, our servers may send a cookie to your computer. Standing alone, cookies do not personally identify you; they merely recognize your web browser.  We may use cookies that are session-based and persistent. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer. Please note that if you disable your web browser’s ability to accept cookies, you will be able to navigate the Website, but you may not be able to successfully use all of the features of the Website.

Google Analytics is an element of the Website. By using cookies, Google Analytics collects and stores data such as time of visit, pages visited, time spent on each page of the Website, the Internet Protocol address, and the type of operating system used in the devices used to access the Website. By using a browser plugin available at http://www.google.com/ads/preferences/plugin/ provided by Google, you can opt out of Google Analytics.

Our legal basis for collecting and using the personal data described in this Privacy Policy will depend on the personal data concerned and the context in which we collect it. We collect personal data from you:

  • where we need it to perform a contract with you (e.g., to fulfill an order);
  • where the processing is in our legitimate interests (which include the purposes listed, above); or
  • if we otherwise have your consent.

3. The Purposes for Which We Use the Data

We use the personal data about you for the following purposes:

  • To communicate with you;
  • To prevent and investigate fraud and other misuses;
  • To protect our rights and/or our property;
  • To operate and improve our products and services;
  • To manage the Portal and the Website;
  • To provide features available on the Website;
  • To set up and maintain your registration with the Portal;
  • To develop, improve, and protect the Website;
  • To market research and electronic direct marketing, in accordance with applicable law;
  • To audit and analyze the Website;
  • For human resource purposes; and
  • To ensure the technical functionality and security of the Website.

4. How We Disclose Data

We do not sell, lease, rent or otherwise disclose the personal data collected from the Website to third parties unless otherwise stated below.

The personal data collected may be disclosed in the following manner:

Personal Data You Provide to Us Directly

We may disclose personal data you provide to us on the Website with the following categories of third parties:

  • Service providers, such as data storage service providers and human resources service providers;
  • Our advertising partners, in accordance with applicable law;
  • Public authorities, such as law enforcement, if we are legally required to do so or if we need to protect our rights or the rights of third parties; and
  • Our subsidiaries and affiliates; or a subsequent owner, co-owner or operator of the Website and/or our services and their advisors in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our stock and/or assets, or in connection with bankruptcy proceedings, or other corporate reorganization, in accordance with this Privacy Policy.

Data Collected Automatically

The data collected automatically on the Website may be disclosed to the following categories of third parties:

  • To service providers, such as data analysis companies;
  • To public authorities, such as law enforcement, if we are legally required to do so or if we need to protect our rights or the rights of third parties; and
  • To our subsidiaries and affiliates; or a subsequent owner, co-owner or operator of the Website and/or our products and services and their advisors in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our stock and/or assets, or in connection with bankruptcy proceedings, or other corporate reorganization, in accordance with this Privacy Policy.

Moreover, we may disclose information to third parties in an aggregate format that does not constitute personal data and does not allow the identification of individual users.

5. Your Rights

You have the following rights with respect to the personal data we hold about you:

  • The right to know what data we hold about you: If you would like to know what personal data we hold about you, through this opt-out form. We seek to promptly respond to your inquiry.
  • The right to have incomplete, incorrect, outdated, or unnecessary personal data corrected, deleted, or updated. If you have questions regarding the correction, deletion, or updating of the personal data we hold about you, please contact us at privacy@unacast.com.
  • The right to opt out of receiving electronic direct marketing communications from us: All electronic direct marketing communications that you may receive from us, such as e-mail messages and SMS-messages, give you an option of not receiving such communications from us in the future. If you have any additional questions about electronic direct marketing received from us, please contact us at privacy@unacast.com.

Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning personal data about you. We encourage you to first reach out to us at privacy@unacast.com so we have an opportunity to address your concerns directly before you do so.

6. Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Website who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@unacast.com or write us at:

Unacast, Inc.

Attn: Chief Privacy Officer

PO Box 216
Cos Cob
152 E Putnam Ave
Cos Cob, CT, 06807-9984

If you are a California resident you may also have the right:

  • To request disclosure of the categories and specific pieces of Personal Data collected about you;
  • To request the disclosure of the business purpose for collecting or selling Personal About you; the categories of third parties with whom it is shared, and the categories of sources from which Personal Data is collected;
  • To request the deletion of Personal Data, subject to the limitations set forth in California Civil Code Section 1798.105(d); and
  • Not to be discriminated against for exercising the rights guaranteed by California Civil Code Section 1798.100 et seq.

For a list of categories of Personal Data collected and the purposes for the processing of that Personal Data, please refer to Sections 2 and 3 above.

In the last 12 months, we have not sold Personal Data collected in and through the Website.

7. Do-Not-Track Settings

California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently isn’t an industry or legal standard for recognizing or honoring DNT signals, we don’t respond to them at this time.

8. Retention of Personal Data

We reserve the right to retain any personal data as long as the personal data are needed to: (i) fulfill the purposes that are described in Section 3 (The Purposes For Which We Use Personal Data), and (ii) comply with applicable law.

9. Data Security

The security of personal data is important to us. We take reasonable measures to protect personal data about you from unauthorized access or against loss, misuse or alteration by third parties. Despite these efforts to store personal data collected on and through the Website and otherwise by us in a secure operating environment that is not available to the public, we cannot guarantee the security of personal data during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of personal data, we cannot guarantee that our security measures will prevent third-parties such as so-called hackers from illegally obtaining access to personal data. We do not warrant or represent that personal data about you will be protected against, loss, misuse, or alteration by third parties.

10. International Transfers of Personal Data

Some elements of the Website and/or our products and services may be hosted on servers located in countries outside your own country. The laws applicable to the protection of personal data in such countries may be different from those applicable in your home country. In particular, if you are located within the European Union, please note that personal data collected by us may be transferred outside the European Union (the “EU”)/ European Economic Area (the “EEA”). In connection with transfers of personal data from the EU/EEA, such transfers are made using adequate safeguards, such as the EU Standard Contractual Clauses for Controller-to-Controller and Controller-to-Processor Transfers.

11. Children’s Privacy

The Website is not directed to children younger than sixteen (16) years of age. We do not intend to collect personal data from children under 16. If you are under 16, please do not use the Website and do not send any information about yourself to us.

11. Changes to the Privacy Policy

From time to time we may change this Privacy Policy. You can tell when changes have been made to the Privacy Policy by referring to the “Last Updated” legend on top of this page. Please review this Privacy Policy regularly to ensure that you are aware of any changes. If we materially change the ways in which we use and disclose personal data, we will post a notice on the Website and send an e-mail to our registered Website visitors. Your continued use of the Website and/or our products and services following any changes to this Privacy Policy constitutes your acceptance of any such changes made.

12. Questions or Concerns?

Should you have any questions regarding this Privacy Policy, your privacy as it relates to the use of the Website, or the protection of the personal data we hold about you, please contact us at privacy@unacast.com. We seek to promptly resolve any concerns you may have.

Opt out

You may opt out of the sale of Personal Information about you by filling out the form here: Do Not Sell My Information

You may also submit opt-out requests by emailing us at privacy@unacast.com.

Opt Out

We wholeheartedly believe that privacy is a concept to which every human that uses a connected device has a fundamental right — and it’s built into every part of our business.

At Unacast we are committed to protecting and respecting data privacy and see privacy as a key driver for the growth of location technologies. Our privacy program covers the flow of location data from the point of collection to our customers’ platforms. Through our partner terms and conditions as well as through reviews of their privacy practices by our designated privacy officers, we strive to ensure that all our partners who contribute location data to us collect, use, and disclose the location data in compliance with applicable privacy laws and industry privacy standards.

We insist, among other things, on:

  • Proper disclosures relating to the collection of location data
  • Respecting user choices in connection with the collection of location data from mobile devices
  • Respecting mobile device users’ choices and device settings

Moreover, we also require that our customers process location data received from us in compliance with applicable privacy laws, industry standards, and their own privacy policies.

Finally, while we do not directly collect any location data, we are mindful about the privacy concerns that the users of mobile devices may have about location data technologies. We describe our own privacy practices relating to the location data we receive from our partners in our Privacy Statement. If you are a visitor to our website, you can read about our privacy practices relating to the data we collect from our website in our Privacy Policy.

You may opt out of the sale of personal information about you by using the form below.

Opt Out Form


You may also submit opt-out requests and other privacy related questions by emailing us at privacy@unacast.com.

Outout Stats

Number of requests to know received and complied with:

54

Requests to delete received and complied with:

16

Requests to opt-out received and complied with:

437

The median or mean number of days taken to respond to each group of requests:

Requests to know:

5.8 days

Requests to delete:

2.4 days

Requests to opt-out:

2.7 days

These opt-out stats are for 2020.

Opt out

You may opt out of the sale of Personal Information about you by filling out the form here: Do Not Sell My Information

You may also submit opt-out requests by emailing us at privacy@unacast.com.

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