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Privacy Statement

Statement about mobile devices and data privacy detailing our approach with respect to data we receive from our partners

LAST UPDATED: December 8, 2016

1. Introduction

Unacast, Inc. and our subsidiaries and affiliates (“Unacast, “we”, “us”) are committed to protecting and respecting data privacy. This Statement explains our approach with respect to data we receive from our partners, such as providers of beacon networks and other so-called proximity technologies (the “Partners”). The technologies provided by the Partners interact with mobile devices in the physical world through mobile applications, 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. For a complete list of our Partners, please see http://unacast.com/partners/.

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

Other than the data we collect on our website, which is subject to a separate privacy policy available at http://unacast.com/privacy-policy/, we do not directly collect data used in our day-to-day business operations ourselves but, instead, obtain data from the Partners.

The Partners may provide the following types of data to us:

  • IDFA and/or advertising identifier (“Advertising ID”);
  • Time stamp for the interaction with the proximity technology;
  • Latitude and longitude of the mobile device when interaction with the proximity technology occurred;
  • The ID of the proximity technology the mobile device interacted with and the corresponding tags and meta data associated with the ID;
  • Mobile device operating system;
  • Mobile device make and model;
  • The name and version of a mobile application name; and
  • The duration of an interaction with a proximity technology (a so-called dwell time).

The Partners do not provide us with data that can be directly used to identify you, such as your name, mobile phone number, or your email address.

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

We analyze, segment and categorize the data provided by the Partners for purposes of providing accurate and relevant advertising across various operating systems and devices and to analyze the effectiveness of advertising campaigns. 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 Data Collection Carried out By the Partners?

Data Collected Through Mobile Applications

a) Privacy Policies

First, please familiarize yourself thoroughly with the privacy policy of any application you download on your mobile device, checking in particular what types of data the application collects from or about your device(s). Do not download, or continue the use of, a mobile application if you do not feel comfortable with the data collection practices described in the applicable privacy policy.

b) Device Settings

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

i) 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.”

ii) 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.

i) iOS

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

ii) 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 with third parties such as advertising networks, advertising publishers, and advertisers, 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. Such disclosures do not include any data that can directly identify a user of a mobile device, such as a name, mobile phone number, or an email address.

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.

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 going to Settings, General, and by clicking on “About”, and on Android by going to Settings, then selecting “Ads”. You can email Unacast at privacy@unacast.com, including the Advertising ID in your email, 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 and it will not have any impact whatsoever on the use or disclosure of an Advertising ID of your mobile device that may be in the possession of any third parties other than Unacast. 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. How Long Does Unacast Keep The Data Provided by our Partners

As a matter of policy, Unacast retains data received from our Partners only for a limited period, as follows:

(i) Data Segments. Data received from our Partners may be categorized into non-personal, non-sensitive demographic segments such as “sports fans” or “concert goers.” We retain such segmented data sets for a period of 24 months from the date they were created.

(ii) Venue Data. We retain an Advertising ID’s association with a certain location, or “venue” such as a sports stadium, for a period of 24 months from the date we receive such data from our Partners.

(iii) Proximity Interactions. We retain an individual mobile device’s interaction with a specific proximity sensor, such as a beacon located in a certain area of an airport, for a period of six (6) months.

Finally, unless we are legally required to do otherwise, we will disassociate a specific Advertising ID from Data Segments, Venue Data, and Proximity Interactions upon your request in accordance with the instruction set out in Section VI above, and retain that Advertising ID only for purposes of blocking it from further use and disclosure by Unacast.

8. European Union Origin Data

Unacast complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union (the “EU”) member countries. Unacast has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. A violation of our commitment to Privacy Shield may be investigated by the Federal Trade Commission and/or the United States Department of Commerce. If there is any conflict between the policies in this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, to the extent available, please visit https://www.privacyshield.gov.

In compliance with the Privacy Shield Principles, Unacast commits to resolve complaints about your privacy and our collection or use of personal information about you. Persons from the EU who have inquiries or complaints regarding this Statement should first contact us via: email at: privacy (at) unacast.com.

Unacast has committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

These recourse mechanisms are available at no cost to you. Damages may be awarded in accordance with applicable law.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, Unacast, Inc. is potentially liable.

9. 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.

10. Questions or Concerns?

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