Privacy Policy & Terms of Service
OUR WARRANTIES AND DISCLAIMERS
WE PROVIDE OUR SERVICES USING A COMMERCIALLY REASONABLE LEVEL OF SKILL AND CARE AND WE HOPE THAT YOU WILL ENJOY USING THEM. BUT THERE ARE CERTAIN THINGS THAT WE DON’T PROMISE ABOUT OUR SERVICES.
OTHER THAN AS EXPRESSLY SET OUT IN THESE TERMS OR ADDITIONAL TERMS, NEITHER COMPANY NOR ITS SUPPLIERS OR DISTRIBUTORS MAKE ANY SPECIFIC PROMISES ABOUT THE SERVICES. FOR EXAMPLE, WE DON’T MAKE ANY COMMITMENTS ABOUT THE CONTENT WITHIN THE SERVICES, THE SPECIFIC FUNCTIONS OF THE SERVICES, OR THEIR RELIABILITY, AVAILABILITY, OR ABILITY TO MEET YOUR NEEDS. WE PROVIDE THE SERVICES “AS IS”.
SOME JURISDICTIONS PROVIDE FOR CERTAIN WARRANTIES, LIKE THE IMPLIED WARRANTY OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT. TO THE EXTENT PERMITTED BY LAW, WE EXCLUDE ALL WARRANTIES.
LIABILITY FOR OUR SERVICES
WHEN PERMITTED BY LAW, COMPANY, AND COMPANY’S SUPPLIERS AND DISTRIBUTORS, WILL NOT BE RESPONSIBLE FOR LOST PROFITS, REVENUES, OR DATA, FINANCIAL LOSSES OR INDIRECT, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES.
TO THE EXTENT PERMITTED BY LAW, THE TOTAL LIABILITY OF COMPANY, AND ITS SUPPLIERS AND DISTRIBUTORS, FOR ANY CLAIMS UNDER THESE TERMS, INCLUDING FOR ANY IMPLIED WARRANTIES, IS LIMITED TO THE AMOUNT YOU PAID US TO USE THE SERVICES (OR, IF WE CHOOSE, TO SUPPLYING YOU THE SERVICES AGAIN).
IN ALL CASES, COMPANY, AND ITS SUPPLIERS AND DISTRIBUTORS, WILL NOT BE LIABLE FOR ANY LOSS OR DAMAGE THAT IS NOT REASONABLY FORESEEABLE.
GENERAL
BY INSTALLING THE MOBILE APPLICATION LINKING TO THIS PRIVACY POLICY, YOU ARE AGREEING TO COMPLY WITH, AND BE BOUND BY, THE FOLLOWING PRIVACY POLICY, AND WHEN APPLICABLE ANY OTHER OPERATING RULES POLICIES, AND OTHER SUPPLEMENTAL TERMS AND CONDITIONS OR DOCUMENTS THAT MAY BE PUBLISHED FROM TIME TO TIME. PLEASE REVIEW THE PRIVACY POLICY CAREFULLY.
THIS APPLICATION COLLECTS INFORMATION AND USES MOBILE ANALYTICS AND INTELLIGENCE SERVICES BY ANONYMOUSLY COLLECTING CERTAIN INFORMATION RELATING TO YOUR USE OF THE APPLICATION AND/OR OTHER APPLICATIONS INSTALLED ON YOUR DEVICE, AND OTHER FUNCTIONS OF YOUR MOBILE DEVICE IN ORDER TO ALLOW THE APPLICATION AND OTHER PARTNERS TO DELIVER ADVERTISEMENTS, PRODUCTS, AND SERVICES THAT ARE RELEVANT AND MEANINGFUL TO THEIR USERS (COLLECTIVELY: THE “SERVICES”).
COMPANY VALUES THE PRIVACY OF ITS CUSTOMERS AND CONSUMERS. COMPANY’S CUSTOMERS INCLUDE CLIENTS OF COMPANY’S SERVICES (DEFINED BELOW), THIRD PARTIES (E.G., PUBLISHERS) THAT PROVIDE DATA TO COMPANY, AS WELL AS BRANDS, ADVERTISING AGENCIES, APPLICATION DEVELOPERS, MEDIA AND TECHNOLOGY PLATFORMS, AND OTHERS WHO VISIT ANY COMPANY WEBSITE THAT LINKS TO THIS POLICY (“SITE”) OR OTHERWISE USE COMPANY’S SERVICES (COLLECTIVELY “CUSTOMERS”). “CONSUMERS” INCLUDE INDIVIDUALS WHO USE COMPANY’S APPLICATIONS OR WHO USE APPLICATIONS FROM WHICH COMPANY RECEIVES OR COLLECTS DATA (SUCH AS APPLICATIONS THAT ARE OWNED AND/OR OPERATED BY COMPANY’S CUSTOMERS).
COMPANY PROVIDES MOBILE APP AUDIENCES AND LOCATION DATA TO ITS CUSTOMERS AND OFFERS A VARIETY OF SERVICES THAT USE THIS DATA. SOME OF COMPANY’S SERVICES RELY SOLELY ON TYPES OF DATA THAT DO NOT PERTAIN TO AN INDIVIDUAL OR DEVICE, WHILE OTHER SERVICES INVOLVE THE USE OF DATA COLLECTED FROM OR ASSOCIATED WITH SPECIFIC CONSUMER DEVICES (“DEVICE DATA” AS FURTHER DEFINED BELOW). THIS PRIVACY POLICY RELATES ONLY TO (A) COMPANY’S SERVICES THAT INVOLVE THE USE OF DEVICE DATA (“SERVICES”) AND (B) COMPANY’S COLLECTION AND USE OF INFORMATION OBTAINED THROUGH COMPANY’S SITE AND APPLICATIONS AS WELL AS IN CONNECTION WITH COMPANY CLIENT ACCOUNTS.
THIS PRIVACY POLICY DOES NOT APPLY TO COMPANIES THAT COMPANY DOES NOT OWN OR CONTROL, INCLUDING COMPANY’S CUSTOMERS. TO LEARN MORE ABOUT HOW COMPANY’S CUSTOMERS COLLECT, USE, AND DISCLOSE INFORMATION ABOUT CONSUMERS, PLEASE VISIT THE CUSTOMERS’ PRIVACY POLICIES.
IF YOU 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, AND YOU CONSENT TO THE TRANSFER OF INFORMATION TO THE U.S. AND THE USE AND DISCLOSURE OF INFORMATION ABOUT YOU, INCLUDING PERSONAL INFORMATION, AS DESCRIBED IN THIS PRIVACY POLICY. COMPANY COMPLIES WITH THE PRINCIPLES OF THE EU-US PRIVACY SHIELD FRAMEWORK (SEE BELOW).
THE CONSUMER INFORMATION COMPANY COLLECTS FOR THE SERVICES
WHEN CONSUMERS USE COMPANY APPLICATIONS OR ENGAGE WITH OUR CUSTOMERS (E.G., BY USING THEIR MOBILE APPLICATIONS OR VIEWING AN AD PROVIDED BY OUR CUSTOMERS, OR BY USING AN APP THAT HAS INTEGRATED OUR SOFTWARE DEVELOPMENT KIT (“SDK”)), WE MAY COLLECT OR RECEIVE DEVICE DATA THAT MAY (BUT DOES NOT NECESSARILY) INCLUDE THE FOLLOWING:
- PRECISE GEOLOCATION DATA PERTAINING TO CONSUMERS’ DEVICES, WHICH MAY BE EXPRESSED BY LATITUDE-LONGITUDE COORDINATES OBTAINED THROUGH GPS TOOLS, WIFI DATA, CELL TOWER TRIANGULATION OR OTHER TECHNIQUES (COLLECTIVELY, “DEVICE GEOLOCATION DATA”) AND LINKED TO AN ANONYMOUS DEVICE IDENTIFIER, SUCH AS THE IDFA FOR IOS DEVICES OR ANDROID ID FOR ANDROID DEVICES;
- OTHER INFORMATION ABOUT A CONSUMER’S DEVICE, SUCH AS: DEVICE TYPE (E.G., TABLET, SMARTPHONE), OPERATING SYSTEM, IP ADDRESS, NETWORK PROVIDER, MOBILE CARRIER, MOBILE BROWSER TYPE (E.G., FIREFOX, CHROME, SAFARI), OTHER APPS AND SDKS INSTALLED ON THE DEVICE, TIMESTAMP, TIME ZONE, INFORMATION ABOUT THE SPEED, BEARING, ORIENTATION, AND ALTITUDE OF A DEVICE, OR OTHER DEVICE-IDENTIFYING INFORMATION;
- INFORMATION ABOUT THE POSSIBLE RELATIONSHIPS AMONG DIFFERENT DEVICES; AND/OR
- DATA ABOUT CONSUMER ACTIVITIES THAT HELPS COMPANY DETERMINE HOW A CONSUMER INTERACTS WITH ADVERTISING OR CONTENT, SUCH AS DETERMINING WHETHER A CONSUMER WHO VIEWED A PARTICULAR ADVERTISEMENT ULTIMATELY PURCHASED THE ADVERTISED PRODUCT OR SERVICE.
HOW COMPANY USES DEVICE DATA TO PROVIDE THE SERVICES
COMPANY GENERALLY USES THE DEVICE DATA IT COLLECTS OR RECEIVES FOR THE FOLLOWING PURPOSES:
- TO OPERATE, MAINTAIN, ENHANCE, AND PROVIDE THE SERVICES DESCRIBED BELOW; AND
- TO IMPROVE AND MARKET THE SERVICES, AND TO CREATE NEW FEATURES AND FUNCTIONALITY.
COMPANY’S SERVICES HELP APPLICATION DEVELOPERS, PUBLISHERS, ADVERTISERS, MARKETERS, AND OTHER COMPANIES AND ORGANIZATIONS LEARN MORE ABOUT CONSUMERS BASED ON DEVICE DATA INCLUDING DEVICE GEOLOCATION AND APPLICATION DATA. FOR EXAMPLE, THE SERVICES HELP CUSTOMERS:
- PROVIDE REALTIME SKY FIELD FOR USER’S CURRENT LOCATION;
- PROVIDE MORE RELEVANT CONTENT OR ADVERTISING TO CONSUMERS OVER TIME AND ACROSS MULTIPLE DEVICES;
- IDENTIFY OTHER CONSUMERS THAT MAY BE INTERESTED IN THEIR OFFERINGS;
- MEASURE THE PERFORMANCE OF CUSTOMER'S CONTENT, SERVICES, AND ADVERTISING (FOR INSTANCE, WHAT EFFECT CERTAIN ADS, AS OPPOSED TO OTHER ADS, HAVE), OR TRENDS OR PREFERENCES AMONG CONSUMERS (FOR INSTANCE, WHAT TYPES OF CONSUMERS GENERALLY TEND TO SHOP AT CERTAIN STORES); OR
- LEARN ABOUT HOW CUSTOMERS’ APPS CAN PERFORM BETTER.
COMPANY MAY ALSO WORK WITH THIRD PARTIES, SUCH AS BRANDS, ADVERTISING AGENCIES, MEDIA PLATFORMS AND PUBLISHERS (SUCH AS APP DEVELOPERS), AND OTHER ADVERTISING PLATFORMS TO IMPROVE THEIR OWN SERVICES. THE ABOVE LIST IS NOT EXHAUSTIVE, BUT IT IS INTENDED TO PROVIDE ILLUSTRATIVE EXAMPLES OF HOW COMPANY USES THE DEVICE DATA IT COLLECTS AND RECEIVES. COMPANY MAY RETAIN THE DEVICE DATA:
- FOR INTEREST-BASED ADVERTISING, AD DELIVERY, AND REPORTING PURPOSES FOR APPROXIMATELY 24 MONTHS;
- FOR OTHER BUSINESS PURPOSES (SUCH AS TECHNICAL DEVELOPMENTS) FOR SUCH PERIOD AS COMPANY CONSIDERS REASONABLY NECESSARY. AFTER THIS COMPANY WILL DELETE OR DE-IDENTIFY THE DEVICE DATA.
COMPANY MAY RETAIN DEVICE DATA BEYOND THESE TIME PERIODS AS REQUIRED BY LAW.
HOW COMPANY DISCLOSES INFORMATION THROUGH THE SERVICES
AS PART OF THE SERVICES, COMPANY MAY PROVIDE DEVICE DATA AND INFORMATION DERIVED FROM DEVICE DATA TO CUSTOMERS AND OTHER THIRD PARTIES. THE USE OF DEVICE DATA BY COMPANY’S CUSTOMERS AND OTHER THIRD PARTIES IS NOT COVERED BY THIS PRIVACY POLICY. SOME OF THESE CUSTOMERS AND OTHER THIRD PARTIES MAY USE COOKIES OR WEB BEACONS (PIXELS) IN ORDER TO SEND TARGETED ADS TO CONSUMERS, ENGAGE WITH CONSUMERS, OR OTHERWISE LOCATE CONSUMERS. FOR MORE INFORMATION ABOUT COOKIES AND WEB BEACONS (PIXELS).
IN ADDITION, COMPANY MAY DISCLOSE DEVICE DATA IF IT BELIEVES THAT SUCH ACTION IS NECESSARY TO COMPLY WITH APPLICABLE LAWS OR REGULATORY INVESTIGATIONS, OR TO RESPOND TO A COURT ORDER, JUDICIAL OR OTHER GOVERNMENT SUBPOENA, WARRANT, OR LAW ENFORCEMENT REQUEST:
- COMPANY MAY ALSO DISCLOSE DEVICE DATA IF IT BELIEVES IT WILL HELP TO PROTECT COMPANY, ITS CUSTOMERS, OR ANY OTHER PERSON OR THIRD PARTY, OR TO ENFORCE ANY LEGAL RIGHTS.
- IN THE EVENT THAT COMPANY IS ACQUIRED BY OR MERGED WITH A THIRD-PARTY ENTITY OR IS POTENTIALLY GOING TO BE ACQUIRED BY OR MERGED WITH A THIRD-PARTY ENTITY, IN ANY PARTIAL OR TOTAL SALE OF ASSETS INCLUDING IN THE EVENT OF BANKRUPTCY, OR IN ANY OTHER CORPORATE CHANGE, COMPANY MAY TRANSFER OR ASSIGN THE DEVICE DATA AS PART OF THAT ACTUAL OR POTENTIAL MERGER, ACQUISITION, SALE, OR OTHER CHANGE OF CONTROL.
- COMPANY MAY SHARE DEVICE DATA WITH ITS AFFILIATES AND JOINT VENTURE PARTNERS.
- COMPANY MAY SHARE DEVICE DATA WITH SERVICE PROVIDERS LIKE ADVERTISER AND ANALYTICS PROVIDER THAT HELP IT OPERATE THE SERVICES.
CONSUMER CHOICES AND HOW TO OPT OUT OF INTEREST-BASED ADVERTISING
OPTING OUT OF INTEREST-BASED ADVERTISING SERVICES BY COMPANY:
COMPANY ADHERES TO THE NAI CODES OF CONDUCT AS DESCRIBED ON THE NAI WEBSITE. COMPANY ALSO ADHERES TO THE DIGITAL ADVERTISING ALLIANCE (DAA) SELF-REGULATORY PRINCIPLES. FOR A DESCRIPTION OF THE DAA PROGRAM, PLEASE VISIT THE DAA WEBSITE. AS DESCRIBED ABOVE, COMPANY MAY USE OR TRANSFER DEVICE DATA THAT IT DIRECTLY COLLECTS OR THAT IT RECEIVES FROM COMPANY’S CUSTOMERS, WHO MAY USE COOKIES OR NON-COOKIE TECHNOLOGIES, TO ENABLE ADVERTISING THAT IS MORE TAILORED TO CONSUMERS’ INFERRED INTERESTS, PREFERENCES, AND LOCATIONS. THIS PRACTICE IS KNOWN AS INTEREST-BASED ADVERTISING. COMPANY MAY ALSO COLLECT, USE OR TRANSFER DEVICE DATA COLLECTED FROM ONE DEVICE FOR INTEREST-BASED ADVERTISING ON OTHER DEVICES THAT MAY BE LINKED TO THE DEVICE WHERE DATA WAS COLLECTED. THIS IS KNOWN AS CROSS-DEVICE LINKING.
COMPANY, AND SOME OF COMPANY’S CUSTOMERS, PROVIDE THE ABILITY FOR CONSUMERS TO OPT OUT OF THE COLLECTION AND USE OF MOBILE APP DATA ACROSS APPS OVER TIME ON A DEVICE, FOR INTEREST-BASED ADVERTISING PURPOSES, THROUGH THE DAA’S APPCHOICES TOOL. TO OPT OUT OF COMPANY’S COLLECTION, USE, AND TRANSFER OF SUCH APP USAGE DATA AND OF DEVICE GEOLOCATION DATA, FOR INTEREST-BASED ADVERTISING PURPOSES, CONSUMERS CAN DOWNLOAD APPCHOICES ONTO THE RELEVANT MOBILE DEVICE AND EXERCISE CHOICE THROUGH THE APP. WHEN SUCH CHOICE IS EXERCISED ON A DEVICE, COMPANY WILL ALSO STOP USING AND TRANSFERRING DEVICE DATA FROM THAT DEVICE FOR INTEREST-BASED ADVERTISING ON OTHER LINKED DEVICES, AND WILL STOP USING DEVICE DATA FROM OTHER LINKED DEVICES FOR INTEREST-BASED ADVERTISING ON THE DEVICE FROM WHICH CHOICE WAS EXERCISED. APPCHOICES IS AVAILABLE AT THE LINKS BELOW:
PLEASE NOTE THAT CONSUMERS WHO USE MORE THAN ONE MOBILE DEVICE SHOULD RENEW THEIR OPT-OUT CHOICES ON EACH DEVICE. CONSUMERS WHO OPT OUT FROM USE OF THEIR DEVICE DATA AS PART OF COMPANY’S SERVICES MAY CONTINUE TO RECEIVE INTEREST-BASED ADVERTISING FROM OTHER COMPANIES.
THIS WILL OPT YOU OUT OF MANY –BUT NOT ALL- OF THE INTEREST-BASED ADVERTISING ACTIVITIES IN WHICH COMPANY OR ITS THIRD PARTY PARTNERS ENGAGE. OPTING OUT VIA APPCHOICES WILL OPT THE USER OUT OF ALL COMPANY TARGETING SEGMENTS THAT ARE CREATED IMMEDIATELY AND ANY SUBSEQUENT SEGMENT DISTRIBUTIONS. HOWEVER, THERE WILL BE A LAG FOR THE USER’S ID TO BE REMOVED FROM PREVIOUSLY DISTRIBUTED TARGETING SEGMENTS THAT ARE ALREADY ACTIVE AT THE TIME WHEN THE OPT-OUT IS EXERCISED.
IF A USER WANTS TO END ALL TARGETING IMMEDIATELY, S/HE CAN TURN ON “LIMIT AD TRACKING” IN HIS/HER DEVICE SETTINGS. TO LIMIT AD TRACK ON AN APPLE DEVICE, SEE INSTRUCTIONS AT: HTTPS://SUPPORT.APPLE.COM/EN-US/HT202074.
TO LIMIT AD TRACKING ON AN ANDROID DEVICE, SEE INSTRUCTIONS AT: HTTPS://SUPPORT.GOOGLE.COM/ADS/ANSWER/2662922.
PLEASE NOTE, HOWEVER, THAT OPTING-OUT WILL NOT BLOCK GENERAL ADVERTISEMENTS THAT ARE SENT AT RANDOM, AND NOT TIED TO THE PERCEIVED INTEREST OF THE USER OF A PARTICULAR DEVICE.
CONSUMERS WHO HAVE DOWNLOADED COMPANY’S APPLICATIONS, BUT WHO NO LONGER WISH TO PROVIDE INFORMATION TO COMPANY FOR INTEREST-BASED ADVERTISING PURPOSES, SHOULD OPT OUT THROUGH APPCHOICES AS DESCRIBED ABOVE.
OPTING OUT OF INTEREST-BASED ADVERTISING ON WEBSITES BY COMPANY CUSTOMERS
COMPANY SOMETIMES WORKS WITH WEB-BASED CUSTOMERS, SUCH AS TO COORDINATE AND INTEGRATE INFORMATION ACROSS PLATFORMS. TO FIND OUT MORE ABOUT INTEREST-BASED ADVERTISING IN THE WEB ENVIRONMENT, AND HOW TO OPT-OUT OF WEB VIEWING INFORMATION COLLECTION FOR THIS PURPOSE BY COMPANIES THAT PARTICIPATE IN THE NETWORK ADVERTISING INITIATIVE OR THE DIGITAL ADVERTISING ALLIANCE, VISIT NAI’S OPT-OUT PAGE OR DAA’S CONSUMER CHOICE PAGE. EEA AND SWISS RESIDENTS PLEASE REFER TO WWW.YOURONLINECHOICES.COM.
ADDITIONAL INFORMATION
COMPANY’S SITE MAY INCLUDE LINKS TO OTHER WEBSITES, APPS, AND SERVICES WHOSE PRIVACY PRACTICES MAY DIFFER FROM COMPANY’S PRACTICES. INFORMATION COLLECTED FROM BY THOSE COMPANIES IS GOVERNED BY THEIR PRIVACY POLICIES OR STATEMENTS.
COMPANY’S SITE MAY OFFER A PUBLICLY ACCESSIBLE BLOG AND/OR A SUPPORT FORUM. ANY INFORMATION PROVIDED IN ANY SUCH AREAS MAY BE READ, COLLECTED, AND USED BY OTHERS INCLUDING THE GENERAL PUBLIC.
COMPANY’S SITE MAY INCLUDE SOCIAL MEDIA FEATURES. THESE FEATURES MAY COLLECT INFORMATION SUCH AS IP ADDRESS OR PAGES(S) VISITED ON COMPANY’S SITE, AND MAY SET A COOKIE TO ENABLE THE FEATURE TO FUNCTION PROPERLY. SUCH FEATURES MAY ALSO COLLECT OR SHARE OTHER INFORMATION AS PERMITTED BY THEIR PRIVACY POLICIES AND A USER’S SETTINGS WITH THE THIRD-PARTY SOCIAL MEDIA COMPANY. SOCIAL MEDIA FEATURES ARE EITHER HOSTED BY A THIRD PARTY OR HOSTED DIRECTLY ON THE SITE. INTERACTIONS WITH THESE FEATURES ARE GOVERNED BY THE PRIVACY POLICY OF THE COMPANY PROVIDING IT.
IN ADDITION TO OTHER INFORMATION DESCRIBED IN THIS POLICY, WE MAY COLLECT AND SHARE PRECISE LOCATION INFORMATION THROUGH METHODS SUCH AS MOBILE “SDKS” BY MEANS OF OUR PARTNERSHIP WITH CUEBIQ, WHICH HELPS COVER THE COSTS OF DEVELOPING AND MAINTAINING THIS APP AND RELATED SERVICES THEREOF. THIS INFORMATION MAY BE USED BY ITSELF, AGGREGATED, OR COMBINED WITH MOBILE IDENTIFIERS, AND MAY BE SHARED WITH OTHER PARTIES, FOR PURPOSES RELATED TO ADVERTISING, ATTRIBUTION (E.G., MEASURING AD PERFORMANCE), ANALYTICS AND RESEARCH. YOU CAN WITHDRAW YOUR CONSENT TO HAVING YOUR LOCATION DATA COLLECTED BY CHANGING THE SETTINGS ON YOUR DEVICE (NOTE THAT CERTAIN SERVICES MAY LOSE FUNCTIONALITY AS A RESULT). YOU CAN ALSO ACTIVATE YOUR DEVICE’S OPT-OUT SETTINGS WHICH WILL: (I) TELL ADVERTISERS TO NOT USE YOUR IN-APP INFORMATION FROM THAT DEVICE FOR PURPOSES OF COLLECTING AND SERVING INTEREST-BASED ADVERTISING AND (II) INFORM CUEBIQ TO HALT FURTHER DATA COLLECTION AND SHARING FROM THAT DEVICE. ADDITIONALLY, YOU CAN OPT-OUT FROM THE CUEBIQ APP DIRECTLY (IOS, ANDROID).
IN ADDITION TO OTHER INFORMATION DESCRIBED IN THIS POLICY, WE MAY COLLECT AND SHARE PRECISE LOCATION INFORMATION THROUGH METHODS SUCH AS MOBILE “SDKS” BY MEANS OF OUR PARTNERSHIP WITH HUQ, WHICH HELPS COVER THE COSTS OF DEVELOPING AND MAINTAINING THIS APP AND RELATED SERVICES THEREOF. THIS INFORMATION MAY BE USED BY ITSELF, AGGREGATED, OR COMBINED WITH MOBILE IDENTIFIERS, AND MAY BE SHARED WITH OTHER PARTIES, FOR PURPOSES RELATED TO ADVERTISING, ATTRIBUTION (E.G., MEASURING AD PERFORMANCE), ANALYTICS AND RESEARCH. YOU CAN WITHDRAW YOUR CONSENT TO HAVING YOUR LOCATION DATA COLLECTED BY CHANGING THE SETTINGS ON YOUR DEVICE (NOTE THAT CERTAIN SERVICES MAY LOSE FUNCTIONALITY AS A RESULT). YOU CAN ALSO ACTIVATE YOUR DEVICE’S OPT-OUT SETTINGS WHICH WILL: (I) TELL ADVERTISERS TO NOT USE YOUR IN-APP INFORMATION FROM THAT DEVICE FOR PURPOSES OF COLLECTING AND SERVING INTEREST-BASED ADVERTISING AND (II) INFORM HUQ TO HALT FURTHER DATA COLLECTION AND SHARING FROM THAT DEVICE.
CALIFORNIA DO NOT TRACK POLICY
CALIFORNIA LAW REQUIRES THAT OPERATORS OF WEBSITES AND ONLINE SERVICES DISCLOSE HOW THEY RESPOND TO A DO NOT TRACK SIGNAL. SOME BROWSERS HAVE INCORPORATED “DO NOT TRACK” FEATURES. MOST OF THESE FEATURES, WHEN TURNED ON, SEND A SIGNAL OR PREFERENCE TO THE WEBSITE OR ONLINE SERVICE THAT A USER VISITS, INDICATING THAT THE USER DOES NOT WISH TO BE TRACKED. BECAUSE THERE IS NOT YET A COMMON UNDERSTANDING OF HOW TO INTERPRET DO NOT TRACK SIGNALS, WE DO NOT CURRENTLY RESPOND TO DO NOT TRACK SIGNAL. USERS MAY ALSO TURN ON “LIMIT AD TRACKING” WHICH WILL ZERO THEIR ADVERTISING IDS AS A MEANS OF OPTING OUT OF TRACKING.
DATA SECURITY
COMPANY USES REASONABLE PHYSICAL, MANAGERIAL, AND TECHNICAL SAFEGUARDS TO PRESERVE THE INTEGRITY AND SECURITY OF USERS’ PERSONAL INFORMATION.
WE TAKE COMMERCIALLY REASONABLE EFFORTS TO MAINTAIN SECURITY PROTECTIONS IN ACCORDANCE WITH INDUSTRY PRACTICES TO PROTECT DATA WE COLLECT FROM LOSS, ALTERATION, DESTRUCTION, MISUSE AND UNAUTHORIZED ACCESS OR DISCLOSURE.
TO PREVENT UNAUTHORIZED ACCESS, MAINTAIN DATA ACCURACY, AND ENSURE THE APPROPRIATE USE OF THE PERSONAL INFORMATION WE COLLECT, WE HAVE IMPLEMENTED PHYSICAL, ELECTRONIC, AND ADMINISTRATIVE PROCEDURES. WE UTILIZE HASHING, ENCRYPTION AND DE-IDENTIFICATION TECHNIQUES TO HELP ENSURE YOUR PRIVACY IS SAFEGUARDED.
WE HAVE POLICIES TO HELP MAINTAIN CONTROL AND PHYSICAL SECURITY OF THE FACILITIES USED TO STORE DATA AND ONLY ALLOW ACCESS TO AUTHORIZED PERSONNEL, RESTRICT ACCESS TO DATA TO THOSE EMPLOYEES, CONTRACTORS AND AGENTS THAT HAVE A NEED TO KNOW THE INFORMATION IN ORDER TO PROVIDE AND SUPPORT OUR SERVICES. ALL OUR EMPLOYEES ARE BOUND BY CONFIDENTIALITY OBLIGATIONS AND MAY BE SUBJECT TO DISCIPLINARY OR LEGAL ACTION IF THEY FAIL TO MEET THESE RESPONSIBILITIES.
WE PROCESS INFORMATION IN A WAY THAT IS COMPATIBLE WITH AND RELEVANT FOR THE PURPOSE FOR WHICH IT WAS COLLECTED. TO THE EXTENT NECESSARY FOR THOSE PURPOSES, WE TAKE REASONABLE STEPS TO ENSURE THAT ANY INFORMATION IN OUR CARE IS ACCURATE, COMPLETE, CURRENT AND RELIABLE FOR ITS INTENDED USE.
CHILDREN’S PRIVACY
COMPANY DOES NOT KNOWINGLY COLLECT PERSONAL INFORMATION FROM CHILDREN UNDER 13 YEARS OLD OR FROM WEBSITES OR ONLINE SERVICES DIRECTED TO CHILDREN UNDER 13 YEARS OLD. USERS SHOULD NOT CREATE ACCOUNTS UNLESS THEY ARE LEGALLY OLD ENOUGH TO FORM A BINDING CONTRACT AND IN ANY CASE ARE 13 YEARS OF AGE OR OLDER. IN THE UNLIKELY EVENT THAT YOU ARE THE PARENT OR LEGAL GUARDIAN OF A CHILD UNDER 13 WHO HAS REGISTERED WITH THE SITE OR SERVICES, PLEASE CONTACT US AT STUDIO.PYOPYO@GMAIL.COM TO HAVE YOUR CHILD’S PERSONAL INFORMATION DELETED.
INTERNATIONAL VISITORS
FOR USERS VISITING THE SITE OR CONSUMERS WHOSE DATA IS COLLECTED THROUGH THE SERVICES FROM NON-U.S. TERRITORIES, PLEASE NOTE THAT ANY DATA ENTERED INTO THE SITE OR THAT IS COLLECTED THROUGH THE SERVICES WILL BE TRANSFERRED OUTSIDE SUCH NON-U.S. TERRITORY FOR USE BY COMPANY AND ITS AFFILIATES FOR ANY OF THE PURPOSES DESCRIBED HEREIN. IN ADDITION, BECAUSE COMPANY OPERATES GLOBALLY, IT MAY MAKE INFORMATION IT GATHERS AVAILABLE TO WORLDWIDE BUSINESS UNITS AND AFFILIATES. BY PROVIDING AND/OR USING ANY DATA ON THE SITE OR THROUGH COMPANY’S SERVICES, INDIVIDUALS HEREBY EXPRESSLY CONSENT TO SUCH TRANSFERS OF DATA TO THE UNITED STATES OR OTHER COUNTRIES.
LINKS TO OTHER (3RD PARTY) WEBSITES AND APPLICATIONS
WE MAY PROVIDE LINKS TO CONTENT OR ADVERTISEMENTS THAT MAY BE CREATED, OFFERED, SPONSORED OR AFFILIATED WITH OTHER ENTITIES. YOUR ACCESS TO AND USE OF SUCH CONTENT AND ADVERTISEMENTS – EVEN WHEN YOU HAVE CLICKED ON A LINK ON THIS WEBSITE TO GET THERE – ARE NOT GOVERNED BY THIS PRIVACY POLICY. INSTEAD, THEY ARE GOVERNED BY THE PRIVACY POLICIES OF THOSE LINKED WEBSITES OR MOBILE APPLICATIONS. COMPANY IS NOT RESPONSIBLE FOR YOUR ACCESS TO AND USE OF SUCH WEBSITES OR APPS, WHICH INCLUDES ANY USE OF PERSONAL INFORMATION THAT MAY BE COLLECTED WHILE YOU VISIT SUCH WEBSITES OR APPS OR WHEN YOU ENGAGE IN ANY TRANSACTIONS WITH THE ENTITIES THAT OPERATE THOSE SITES OR APPS. WE STRONGLY RECOMMEND THAT YOU CAREFULLY REVIEW THESE ENTITIES’ PRIVACY POLICIES AND TERMS OF USE/ACCEPTABLE USE POLICIES BEFORE SUBMITTING PERSONAL INFORMATION TO THEM.
LINK TO PRIVACY POLICY OF THIRD PARTY SERVICE PROVIDERS USED BY OUR APPS:
OPENSIGNAL CONNECTIVITY ASSISTANT
MORE INFORMATION FOR INDIVIDUALS FROM THE EUROPEAN ECONOMIC AREA (“EEA”) AND SWITZERLAND EU-U.S. PRIVACY SHIELD AND U.S.-SWISS SAFE HARBOR
COMPANY COMPLIES WITH THE EU-U.S. PRIVACY SHIELD FRAMEWORK AS SET FORTH BY THE U.S. DEPARTMENT OF COMMERCE REGARDING THE COLLECTION, USE, AND RETENTION OF PERSONAL DATA FROM EEA MEMBER COUNTRIES, AS THAT TERM IS DEFINED IN THE PRIVACY SHIELD FRAMEWORK. COMPANY HAS CERTIFIED 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. TO LEARN MORE ABOUT THE PRIVACY SHIELD PROGRAM, AND TO VIEW OUR CERTIFICATION PAGE, PLEASE VISIT HTTPS://WWW.PRIVACYSHIELD.GOV/.
ADDITIONALLY, COMPANY COMPLIES WITH 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 SWITZERLAND. COMPANY 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 US-SWISS SAFE HARBOR AND TO VIEW OUR CERTIFICATION PAGE, PLEASE VISIT HTTP://WWW.EXPORT.GOV/SAFEHARBOR/.
RESIDENTS OF THE EEA AND SWITZERLAND HAVE THE RIGHT TO ACCESS THE PERSONAL DATA THAT COMPANY MAINTAINS ABOUT YOU, AS THAT TERM IS DEFINED IN THE PRIVACY SHIELD FRAMEWORK, AND YOU MAY BE ABLE TO CORRECT OR AMEND THAT INFORMATION IF IT IS INACCURATE OR HAS BEEN PROCESSED IN VIOLATION OF THE PRIVACY SHIELD PRINCIPLES, TO THE EXTENT ALLOWED BY LAW. TO EXERCISE THIS RIGHT, PLEASE EMAIL STUDIO.PYOPYO@GMAIL.COM. FOR INFORMATION ON OPTING OUT OF INTEREST-BASED ADVERTISING ENABLED BY COMPANY, PLEASE SEE SECTION “CONSUMER CHOICES AND HOW TO OPT OUT OF INTEREST-BASED ADVERTISING” ABOVE.
COMPANY IS ACCOUNTABLE FOR INFORMATION THAT IT RECEIVES UNDER THE PRIVACY SHIELD AND SUBSEQUENTLY TRANSFERS TO A THIRD PARTY. IN PARTICULAR, COMPANY IS RESPONSIBLE UNDER THE PRIVACY SHIELD PRINCIPLES IF THIRD-PARTY CONTROLLERS TO WHOM IT TRANSFERS INFORMATION OR THIRD-PARTY AGENTS IT ENGAGES TO PROCESS THIS INFORMATION ON ITS BEHALF DO SO IN A MANNER INCONSISTENT WITH THE PRINCIPLES.
COMPANY COMMITS TO RESOLVE COMPLAINTS ABOUT OUR COLLECTION OR USE OF YOUR PERSONAL DATA. RESIDENTS OF THE EEA OR SWITZERLAND WITH INQUIRIES OR COMPLAINTS REGARDING THIS PRIVACY POLICY SHOULD FIRST CONTACT COMPANY AT:
STUDIO.PYOPYO@GMAIL.COM
COMPANY HAS FURTHER COMMITTED TO REFER UNRESOLVED PRIVACY COMPLAINTS UNDER THE EU-US PRIVACY SHIELD PRINCIPLES OR THE U.S.-SWISS SAFE HARBOR TO JAMS. IF YOU DO NOT RECEIVE TIMELY ACKNOWLEDGMENT FROM COMPANY OF YOUR COMPLAINT, OR IF YOUR COMPLAINT IS NOT SATISFACTORILY ADDRESSED, PLEASE VISIT HTTPS://WWW.JAMSADR.COM/EU-US-PRIVACY-SHIELD FOR MORE INFORMATION AND TO FILE A COMPLAINT. A BINDING ARBITRATION OPTION MAY ALSO BE MADE AVAILABLE TO YOU IN ORDER TO ADDRESS COMPLAINTS NOT RESOLVED BY ANY OTHER MEANS.
COMPANY IS SUBJECT TO THE INVESTIGATORY AND ENFORCEMENT POWERS OF THE UNITED STATES FEDERAL TRADE COMMISSION.
WHAT IS THE LEGAL BASIS ON WHICH COMPANY RELIES TO PROCESS PERSONAL DATA?
ON SOME OCCASIONS, COMPANY MAY PROCESS PERSONAL DATA WITH THE INDIVIDUAL’S CONSENT (FOR EXAMPLE, WHEN A USER AGREES THAT COMPANY MAY PLACE COOKIES, OR PROCESS INFORMATION THAT THE USER INPUTS INTO THE COMPANY WEBSITE).
ON OTHER OCCASIONS, COMPANY MAY PROCESS PERSONAL DATA WHEN COMPANY NEEDS TO DO THIS TO FULFILL A CONTRACT (FOR EXAMPLE, FOR BILLING PURPOSES) OR WHERE COMPANY IS REQUIRED TO DO THIS BY LAW.
COMPANY ALSO PROCESSES A USER’S/CONSUMER DATA WHEN IT IS IN COMPANY’S OR ITS CUSTOMER’S LEGITIMATE INTERESTS TO DO THIS AND WHEN THESE INTERESTS ARE NOT OVERRIDDEN BY THE INDIVIDUAL’S DATA PROTECTION RIGHTS. THOSE LEGITIMATE INTERESTS INCLUDE PROVIDING SERVICES TO ENABLE COMPANY’S CUSTOMERS TO PROVIDE MORE RELEVANT ADS AND CONTENT.
WHO IS RESPONSIBLE FOR THE DATA?
FOR THE MAJORITY OF THE SERVICES IT OFFERS, COMPANY, INC. IS A DATA PROCESSOR WHO PROCESSES DATA ON BEHALF OF ITS CUSTOMERS. FOR CERTAIN OTHER SERVICES FOR WHICH COMPANY IS A DATA CONTROLLER AND FOR PROCESSING OF PERSONAL DATA DERIVED FROM THE SITE, COMPANY, INC. IS THE DATA CONTROLLER OF THE DATA.
IF YOU HAVE ANY QUESTIONS OR COMMENTS PLEASE CONTACT COMPANY AT THE CONTACT DETAILS SET OUT AT SECTION “ADDITIONAL INFORMATION” BELOW.
YOUR RIGHTS
YOU MAY ASK COMPANY FOR A COPY OF YOUR INFORMATION, TO CORRECT IT, ERASE IT, AND TO TRANSFER IT TO OTHER ORGANIZATIONS AT YOUR REQUEST. YOU ALSO HAVE RIGHTS TO OBJECT TO SOME PROCESSING AND, WHERE COMPANY HAS ASKED FOR YOUR CONSENT TO PROCESS YOUR DATA, TO WITHDRAW THIS CONSENT. COMPANY WILL ONLY SEND MARKETING TO YOU, IF YOU HAVE INDICATED THAT YOU ARE HAPPY TO RECEIVE MARKETING INFORMATION FROM US. IN ADDITION, YOU HAVE RIGHTS TO OBJECT TO DIRECT MARKETING AT ANY TIME. WHERE COMPANY PROCESSES YOUR DATA BECAUSE COMPANY HAS A LEGITIMATE INTEREST IN DOING SO (AS EXPLAINED ABOVE), YOU ALSO HAVE A RIGHT TO OBJECT TO THIS. THESE RIGHTS MAY BE LIMITED IN SOME SITUATIONS – FOR EXAMPLE, WHERE COMPANY CAN DEMONSTRATE THAT IT HAS A LEGAL REQUIREMENT TO PROCESS YOUR DATA.
COMPANY HOPES TO SATISFY QUERIES YOU MAY HAVE ABOUT THE WAY COMPANY PROCESSES YOUR DATA. FOR DETAILS ON HOW TO OPT-OUT OF COMPANY’S INTEREST-BASED ADVERTISING SERVICES, PLEASE SEE SECTION “CONSUMER CHOICES AND HOW TO OPT OUT OF INTEREST-BASED ADVERTISING” ABOVE.
HOWEVER, IF YOU HAVE UNRESOLVED CONCERNS YOU MAY ALSO HAVE THE RIGHT TO MAKE A COMPLAINT TO THE RELEVANT DATA PROTECTION SUPERVISORY AUTHORITY OR TO SEEK A REMEDY THROUGH THE COURTS IF YOU BELIEVE THAT YOUR RIGHTS HAVE BEEN BREACHED.
CHANGES AND UPDATES TO THIS PRIVACY POLICY
THIS PRIVACY POLICY MAY BE REVISED PERIODICALLY WITHOUT FURTHER NOTICE. TO STAY AWARE OF ANY CHANGES, PLEASE REVISIT THIS PAGE REGULARLY.
ABOUT THESE TERMS
IF YOU DO NOT COMPLY WITH THESE TERMS, AND WE DON’T TAKE ACTION RIGHT AWAY, THIS DOESN’T MEAN THAT WE ARE GIVING UP ANY RIGHTS THAT WE MAY HAVE (SUCH AS TAKING ACTION IN THE FUTURE).
IF IT TURNS OUT THAT A PARTICULAR TERM IS NOT ENFORCEABLE, THIS WILL NOT AFFECT ANY OTHER TERMS. THE LAWS OF COUNTRIES AND REGIONS WILL APPLY TO ANY DISPUTES ARISING OUT OF OR RELATING TO THESE TERMS OR THE SERVICES.
COMPANY CONTACT INFORMATION
PLEASE CONTACT COMPANY, INC. WITH ANY QUESTIONS OR COMMENTS ABOUT THIS PRIVACY POLICY OR THE COMPANY’S PRACTICES AT:
STUDIO.PYOPYO@GMAIL.COM