Hexagon

Privacy

Looking beyond GDPR to the future of privacy

Our clients trust us to put privacy front and center. We are compliant with GDPR and CCPA — and our own privacy guidelines go beyond legislation.

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 proximity 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 proximity 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 proximity data, we are mindful about the privacy concerns that the users of mobile devices may have about proximity technologies. We describe our own privacy practices relating to the proximity 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: June 3, 2019

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?

In addition to the data provided by our Partners, we receive data through our software development kit (“SDK”) included in Apps of some of our Partners. Some of the data we receive from the Partners or through the SDK may constitute Personal Data under applicable laws.

The data provided by the Partners and the SDK 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)
  • Nearby SSID or BSSID and the signal strength

The data provided by our Partners and the data collected by means of the SDK does not include data that directly identifies you, such as your name, mobile phone number, or your email address.

We process the data provided by the Partners and the data collected by the SDK based on our legitimate interest of providing, improving, and analyzing our location-based products and services and, where appropriate or as required by law, 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 balance our legitimate interests with the privacy interests of the users of mobile devices and incorporate privacy-enhancing technologies such as data aggregation and data retention limitations into our data processing platform.

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 and the SDK 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 and the data collected by the SDK 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. 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.

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 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. 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 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, you may submit a request to privacy@unacast.com. 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 My Data?

As a matter of policy, Unacast retains data received from our Partners as long as the data is needed for the purposes described above in Section 3 or as long as required by law.

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. Personal Data Transferred from the EU or Switzerland to the United States

Unacast complies with the EU-US Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (Privacy Shield) as set forth by the US Department of Commerce regarding the collection, use, and retention of personal data transferred from the EU and the United Kingdom and/or Switzerland, as applicable to the United States in reliance on Privacy Shield. 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 data about you. Persons from the EU who have inquiries or complaints regarding this Statement should first contact us via email at: privacy@unacast.com.

Unacast has committed to refer unresolved privacy complaints under the Privacy Shield Principles to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit for more information and to file a complaint.

Additionally, with respect to complaints concerning human resources data that is transferred from the EU to the United States, we have agreed to participate in the dispute resolution procedures of the EU Data Protection Authorities. Contact details for the EU data protection authorities can be found at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. Unacast will cooperate with the appropriate EU Data Protection Authorities during investigation and resolution of complaints concerning human resources data that is transferred from the EU to the United States under the Privacy Shield.

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

Under certain conditions, if you are not satisfied with the above recourse mechanism, you may be able to invoke binding arbitration.

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.

Pursuant to the Privacy Shield, Unacast remains liable for the transfer of personal data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages.

10. Your California Privacy Rights

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your 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

11. 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.

12. 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: February 11, 2019

1. Introduction

Unacast, Inc. and our subsidiaries and affiliates (“Unacast, “we”, “us”) are committed to protecting and respecting your privacy. This Privacy Policy (together with our Terms of Use and any other documents referred to in it) 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 (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. 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 goods 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. 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

In this Section 2 we describe the personal data we collect.

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 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;

  • Company name;
  • First name, Last name;
  • Phone number;
  • Website;
  • Email address;
  • Location; and
  • 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 personal data related to recruitment / job applications. Moreover, if you contact us, a record of this correspondence may be kept.

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 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:

  • Information about the devices you use to access the Website and Services (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 and Services (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. Unless you choose to identify yourself to us, either by responding to a promotional offer, or filling out a web form, you remain anonymous to us.

We may use cookies that are session-based and persistent-based. 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 Website;
  • To provide features available on the Website;
  • To set up and maintain your registration with the Proximity Directory service;
  • 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, please contact us at privacy@unacast.com. 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

245 Fifth Avenue, Suite 1101

New York, NY 10016

7. 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 the Data), and (ii) comply with applicable law.

8. 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.

9. 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”). You consent to personal data about you being transferred outside your own country and, where applicable, outside the EU.

10. Personal Data Transferred From the EU or Switzerland to the United States

Unacast complies with the EU-US Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (Privacy Shield) as set forth by the US Department of Commerce regarding the collection, use, and retention of personal data transferred from the EU and the United Kingdom and/or Switzerland, as applicable to the United States in reliance on Privacy Shield. 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 data about you. Persons from the EU who have inquiries or complaints regarding this Statement should first contact us via email at: privacy@unacast.com.

Unacast has committed to refer unresolved privacy complaints under the Privacy Shield Principles to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment 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.

Additionally, with respect to complaints concerning human resources data that is transferred from the EU to the United States, we have agreed to participate in the dispute resolution procedures of the EU Data Protection Authorities. Contact details for the EU data protection authorities can be found at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. Unacast will cooperate with the appropriate EU Data Protection Authorities during investigation and resolution of complaints concerning human resources data that is transferred from the EU to the United States under the Privacy Shield.

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

Under certain conditions, if you are not satisfied with the above recourse mechanism, you may be able to invoke binding arbitration.

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.

Pursuant to the Privacy Shield, Unacast remains liable for the transfer of personal data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages.

11. Children’s Privacy

The Website is not directed to children younger than thirteen (13) years of age. We do not intend to collect personal data from children under 13. If you are under 13, please do not use the Website and do not send any information about yourself to us.

12. 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 users. 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.

13. 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.