Effective as of May 25, 2018
Updated as of July 28, 2020
For the purpose of applicable data protection legislation, depending on our role in data processing activities, we may be the data controller or data processor of your personal data.
We will post any modifications or changes to the Policy on our Site. We reserve the right to modify the Policy at any time, so we encourage you to review it frequently. If we make any material changes to the Policy, we will notify you prior to such changes take effect.
Purposes of Processing
What is personal data?
We collect information about you in a range of forms, including personal data. As used in this Policy, “personal data” is as defined in the General Data Protection Regulation 2018 and any successor legislation, this includes any information which, either alone or in combination with other information we hold about you, identifies you as an individual, including, for example, your name, postal address, email address and telephone number.
Why do we need your personal data?
We will only process your personal data in accordance with applicable data protection and privacy laws. We need certain personal data in order to provide you with access to the Site.
Collecting Your Personal Data
We collect information about you in the following ways:
Information You Give Us. This includes the personal data you provide when you conclude an agreement with us; the personal data provided in connection with our applications we run on the Site or by other third parties; the personal data you provide when you report a problem or when we provide you with customer support; the personal data you provide when you make a purchase; and the personal data you provide when you correspond with us by phone, email or otherwise.
Information Automatically Collected. We automatically log information about you and your computer or mobile device when you access our Site. For example, when visiting our Site, we log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Site.
We collect this information about you using cookies. We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site. We collect analytics and performance cookies. We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies. You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html. You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org.
Using Your Personal Data
We may use your personal data as follows: to operate, maintain, and improve our Site, products, and services; to manage your subscription, including to communicate with you; to operate and administer our payment system; to respond to your comments and questions and to provide customer service; to send information including technical notices, updates, security alerts, and support and administrative messages;
with your consent, to send you marketing e-mails about upcoming promotions, and other news, including information about products and services offered by us and our affiliates. You may opt-out of receiving such information at any time. Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails; to process payments; to link or combine user information with other personal data; as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others; and as described in the “Sharing of your Personal Data” section below.
Sharing Your Personal Data
We may share your personal data as follows:
Third Parties Designated by You. We may share your personal data with third parties where you have provided your consent to do so.
Our Third Party Service Providers. We may share your personal data with our third party service providers who provide services such as data analysis, payment processing, information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services. These third parties are only permitted to use your personal data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your personal data.
Affiliates. We may share some or all of your personal data with our affiliates, in which case we will require our affiliates to comply with this Policy.
Other Disclosures. We may share personal data as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.
When we use the term “anonymous data,” we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party.
We may create anonymous data from the personal data we receive about you and other individuals whose personal data we collect. Anonymous data might include analytics information and information collected by us using cookies or via applications on third parties website. We make personal data into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you.
Third Party Sites
Our Site may contain links to third party websites and features. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their websites, features or policies. Please read their privacy policies before you submit any data to them.
We seek to use reasonable organizational, technical and administrative measures to protect personal data within our organization. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us.
We will only retain your personal data as long reasonably required for you to use the Site unless a longer retention period is required or permitted by law (for example for regulatory purposes).
Opt-out. You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of sensitive personal data; (iv) any new processing of your personal data that we may carry out beyond the original purpose; or (v) the transfer of your personal data outside the EEA. Please note that your use of some of the Site may be ineffective upon opt-out.
Access. You may access the information we hold about you at any time by contacting us directly.
Amend. You can also contact us to update or correct any inaccuracies in your personal data.
Portability. Your personal data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.
Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.
If you wish to exercise any of these rights, please contact us. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the personal data associated with the particular person, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.
We are committed to resolve any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us.
Huq Industries Limited (2nd Floor 58-64 City Rdt, London, EC1Y 2AL, UK, firstname.lastname@example.org)
To help us improve our service we collect the following information on an anonymous basis: Operating System, Date & time, Latitude, Longitude, Accuracy (GPS), SSID (network), BSSID (network), Internal MAC address (network), Bundle ID, Device Model, Device Manufacturer, Carrier Code (Android only), Carrier Name, Sim Code, Country, and Locale.
In addition to helping us to measure the usage of our SDK this anonymous information is shared with third parties for their business purposes, including the creation of reports, market research and trend analysis. One of these third parties is Huq, data shared does not contain information from which users can be identified and we will not provide additional information to such third parties that enables such third parties to identify you.
You can find a full description of Huq and what it does with the information collected via our SDK here.
OpenSignal, Inc (94 Durharm Road, London, N2 9DS, UK, email@example.com)
OpenSignal collects data on mobile network coverage and performance. We use the crowdsourced data collected from users’ devices to publish reports and metrics on mobile network experience. You can see the reports we publish here: http://opensignal.com/reports.
OpenSignal is the independent global standard for measuring real-world mobile network experience. We believe measuring how the network performs directly through users’ eyes is key to building better wireless networks.
Tutela Technologies Ltd. (320 – 838 Fort St, Victoria BC V8W 1H8, Canada, firstname.lastname@example.org)
Tutela Technologies Ltd. is a world leader in improving wireless networks based on users’ perspective of performance. Tutela may collect data relating to the wireless network performance your device experiences, in a pseudonymized manner, that may include the following categories of personal information and/or personal data:
- Geolocation data. Precise location information (GPS and network-based) may be collected to aggregate and plot network performance on a map to convey coverage.
- Identifiers. Device identifiers including Mobile Advertising ID may be collected to help mobile enterprises identify network technologies (e.g. 5G), understand drivers of churn/acquisition, and design effective marketing campaigns.
- Internet or other electronic network activity information. The state of this application during a network test (e.g. “in use”) may be collected for data validation purposes. Tutela never sees or records any content viewed by users.
Using this app and permitting Tutela to collect pseudonymous data may help improve the performance of your wireless network and apps. Tutela combines data collected from millions of devices to create reports and solutions trusted by mobile enterprises around the world. This pseudonymous data may be shared with mobile network operators, network equipment manufacturers, and other third parties who use it to benchmark, compare, and understand the mobile industry, design effective marketing campaigns, and plan and optimize their networks.
Tutela never collects your sensitive personal information, name, phone number, or e-mail, and takes technical and administrative measures to ensure data is not attributed to particular consumers. For further information about Tutela’s data practices please see the Tutela Privacy Charter. You have the right to opt-out of data sharing with Tutela. To do so, please utilize the opt-out measures provided in your mobile application or this privacy statement, or visit Do Not Sell My Info.
X-Mode Social, Inc. (45662 Terminal Drive, Dulles VA, 20164 email@example.com)
X-Mode Social, Inc. collects and passes to third parties a variety of information for use as described below:
What’s Collected: Precise location information (such as your device GPS coordinates), relative location information (from WiFi signals or Bluetooth Low Energy devices in your proximity, for example), device-based advertising identifiers, information about your mobile device such as type of device, operating system version and type, device settings, time zone, carrier and IP address.
When We Collect It: When the app is in use or running in the background.
How We Use and Share It: We and other third parties may use the information (a) to customize ads in this or other apps (for instance, if your device is often located at or near music venues, you might receive offers for music tickets); (b) to measure effectiveness of those ads; (c) for disease prevention and research, security, anti-crime and law enforcement; or (d) for market, civic or other research regarding aggregated traffic patterns (for instance, a company that analyzes shopping trends might want to learn whether more or fewer devices are seen near malls or in other shopping districts).
Predicio (99 rue de Sèvres, 75006, Paris, France, firstname.lastname@example.org)
Beintoo S.P.A.(Largo Richini 2, Milano, Italy, email@example.com)
Upon express authorization of the user, this app can collect and transmit to Beintoo Spa location data connected to the mobile device.
Beintoo is an Italian mobile data company, whose service connects to each device an identification code that allows you to locate the position of the device itself via Wi-Fi or GPS, even offline. If the User has expressly authorized such possibility, Beintoo can receive information on its actual geographical position and on the time the User stays in a particular place.
Once consent is given, it will always be possible to revoke it, by opting out as explained below. The collected data can be used for the profiling of users for advertising purposes, statistical analysis, and attribution. The personal data collected are: Usage data, unique identifiers of devices for advertising (Google Advertiser ID or IDFA identifier) and geographical location (only if the option is enabled on your device).