Hexagon

Privacy

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: November 1, 2020

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 with third parties such as advertising networks, advertising publishers, and advertisers, research companies, data brokers, financial institutions, data analytics platforms, 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.

For a list of these third parties, and a link to their privacy policies, please see below:

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 instruction 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.

245 Fifth Avenue, Suite 1101

New York, NY 10016

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 patters of the actual user of the device.  Given this risk, and (i) since we do not seek to determine the actual identify 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

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 Data Protection Officer 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.