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:
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.
Last Updated: November 1, 2020
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.
Some of the data we receive from the Partners may constitute Personal Data under applicable laws.
The data provided by the Partners may include:
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.
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.
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.
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.
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:
For a list of these third parties, and a link to their privacy policies, please see below:
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.
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 firstname.lastname@example.org, so we have an opportunity to address your concerns directly before you do so.
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.
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.
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 email@example.com or write us:
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:
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 firstname.lastname@example.org.
(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
The data provided by our Partners does not include Personal Data relating to children younger than sixteen (16) years of age.
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.
Should you have any questions regarding this Statement or your privacy, please contact our Data Protection Officer at email@example.com. We seek to promptly resolve any questions or concerns you may have.
Last Updated: April 7, 2020
In this Section 2 we describe the personal data we collect.
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 contact us via the Website; and when you otherwise communicate with us.
The information you provide to us directly may include, without limitation, the following information that may, in certain circumstances, constitute personal data:
Subscribing to our Mailing List: If you wish to subscribe to our mailing list, we collect your name and email address. In this context, we may also collect data concerning your device (as further described below) to serve you with more personalized emails;
Other information: We may also collect any other information you may want to share with us, such as personal data related to recruitment / job applications. Moreover, if you contact us, a record of this correspondence may be kept.
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:
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 our Site. 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 and Hotjar) that collect information about use of the Website and Services and user traffic. The information we may collect by automated means may include, without limitation:
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.
We use the personal data about you for the following purposes:
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:
We may disclose personal data you provide to us on the Website with the following categories of third parties:
The data collected automatically on the Website may be disclosed to the following categories of third parties:
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.
You have the following rights with respect to the personal data we hold about you:
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 firstname.lastname@example.org so we have an opportunity to address your concerns directly before you do so.
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 email@example.com or write us at:
Attn: Chief Privacy Officer
245 Fifth Avenue, Suite 1101
New York, NY 10016
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 the Data), and (ii) comply with applicable law.
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.
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”). You consent to personal data about you being transferred outside your own country and, where applicable, outside the EU.
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.