VISITORS OF THE SPOTEER SITE AND PLATFORM
In general, you may visit the Spoteer site and platform without telling us who you are or revealing any information about yourself. When you contact us or submit an inquiry via the Spoteer site and platform or platform, we may collect personal information from you, which may include your name, address, email address, and phone number (collectively, information that we define as “Personal Information”). We may use Personal Information internally for our general commercial purposes, including, among other things, to respond to your inquiries.
In addition, we may automatically collect non-personal information (collectively, “Analytics”) from your desktop computer, laptop, mobile phone, tablet, or other consumer electronic device that you use to access the Spoteer site and platforms and/or services (each, a “Device”). Analytics may include technical information about your Device (such as the Device type, operating system, settings and system configurations, IP address, Device ID and other unique Device identifiers, and mobile network information) and your activity using the Spoteer site and platform and/or services (such as data about the webpages you access, traffic to and from websites, the dates and times associated with transactions, web log data, and other event information, including crashes and system activity). We may use Analytics for research and commercial purposes, such as to improve the Spoteer site and platform so that it is more useful and accessible to you and provide relevant advertising to you. Analytics may be correlated with your Personal Information.
We collect Analytics using certain technologies, such as:
Cookies. Cookies are small data files that have unique identifiers and reside, among other places, on your Devices, in emails we send to you, and on the web pages of the Spoteer site and platform and platform. Among other things, cookies help us improve and personalize your use of the Spoteer site and platform and platform. We may permit certain third parties to place cookies through the Spoteer site and platform to provide us with better insights into the use of the Spoteer site and platform and user demographics and to provide relevant advertising to you. These third parties may collect information about your online activities over time and across different websites when you use the Spoteer site and platform. For example, we utilize Google Analytics to analyze usage patterns for the Spoteer site and platform and platform. Google Analytics generates a cookie to capture information about your use of the Spoteer site and platform that Google uses to compile reports on website activity for us and to provide other related services. Google may use a portion of your IP address to identify its cookie and for its commercial purposes.
Web Beacons. Web beacons are electronic images that may be used on the Spoteer site and platform or in emails we send to you. We use web beacons to deliver cookies, count visits, understand usage and effectiveness of offers, and tell whether you open an email and act upon it.
Do Not Track. Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not currently respond to DNT signals.
We may share Personal Information collected from visitors of the Spoteer site and platform as described below.
END USERS OF APPS USING SPOTEER AND DESCRIPTION OF OUR SERVICES
Spoteer is an advertising and data management platform that focuses on the collection and use of precise location data & other information, to help advertisers provide more relevant offers to end users. Spoteer receives this data and information either from an SDK that it provides to mobile applications (“apps”), or from a server-to-server transfer and/or integration with mobile app partners.
This data and information generally includes lat/long data, i.e., GPS-level data, and/or WiFi data (if feasible) associated with a unique mobile identifier, be that IMEI, mobile advertising ID, such an IDFA or an Android advertising ID, MAC addresses etc.
We use the information we collect to make inferences about what types of activities users tend to spend time doing. For instance, we may notice a particular Device frequently at locations associated with sports (e.g., an arena), music (e.g., a concert venue), eating out (e.g., restaurants) or health and fitness (e.g., a gym or health club).
We use this and other information to categorize Device users into “interest segments – which advertisers can use to target digital out of home ads when those users appear in the vicinity of a digital billboard or other outdoor/indoor digital advertising device.
We also use the information we collect to help advertisers analyze ad performance – such as by measuring whether or how an end user that saw a particular ad tended to engage with a product or brand.
In addition, we sometimes use this information to help advertisers better understand their customers or their marketing, such as for market research, customer analytics, or analytics of traffic patterns.
We refer to all of the above services as the “Services.”
INFORMATION COLLECTED BY THE SPOTEER SERVICES
When you have accessed or used an App that uses the Services, the Publishers of such App may allow us to automatically collect information about your Device and your activity and interaction with such App (“Information”), which may include:
- IP address
- Geolocation and proximity of your Device if location services are enabled on your Device
- Unique Device identifiers for advertising (Google Advertiser ID or IDFA)
- System configuration information
- Time and date information
- List of apps installed on your device
- Browsing history
- Personal Email address
- Other non-personal information that Publishers share with us
- Dwell time near points of interest, as determined through beacon, Wi-Fi, GPS and other signals as discussed below and our proprietary systems
That Information is sent to our server through an API in encrypted form, via an HTTPS protocol.
Advertisers and partners use our software development kit and/or integrate with our API to use the Services more effectively. We collect Information from such Apps.
We also collect Information from third-party devices present at certain third-party locations, such as stores, shopping malls, stadiums, bars, restaurants, and other points of interest. Such devices may use Wi-Fi, near field communication (NFC), or Bluetooth low-energy (BLE) beacon technology to transmit signals about the location of your Device to us.
We may use Information to provide and improve the Services, including, but not limited to, the following purposes:
- To develop and use predictive models to predict End Users’ potential future behavior and interests on a per-Device basis and across Devices
- To provide targeted advertising to End Users, including through the creation of user interest categories
- To attribute End Users’ visits to stores or other specific points of interest for advertising campaigns
- To help Publishers enhance their user profiles
We may share Information, and our Analytics related thereto, to provide and improve the Services and as follows:
- With Publishers for their advertising, analytics, or other purposes
- With Advertisers so they may provide targeted content and advertising to you on websites and mobile applications
- With other third parties, such as demand-side, advertising platforms, data management platforms, advertising agency trading desks, proximity solution providers, advertising technology providers, so they may provide targeted content and advertising to you on third-party websites, mobile applications, and other advertising mediums
Sometimes, we may provide information (such as IP address, but excluding precise lat/long coordinates) to third party platforms, connected to interest segments, to help advertisers identify common users across different Devices or browsers – for instance, to identify a common set of users on both mobile Devices or tablets, as well as the web.
HOW WE USE INFORMATION WE COLLECT
- Provide the Spoteer Site and the Services and notices related thereto
- Provide customer support for the Spoteer Site and the Services
- Detect and protect against errors, fraud, or other criminal activity
- Collect fees and other amounts owed in connection with the Spoteer Site and the Services
- Analyze, customize, and improve the Spoteer Site and the Services
- Deliver targeted marketing and promotional offers to you
- Contact you by email message, push notifications, voice call, or text message, subject to applicable law
We do not use Information for employment eligibility, credit eligibility, health card eligibility, or insurance eligibility, underwriting, or pricing purposes.
We may also use your Information to analyze information in order to offer anonymized and aggregated data, market research, and business intelligence or information products to third parties.
HOW WE SHARE INFORMATION WE COLLECT
- If the information is provided to help complete a transaction requested by you
- To allow third parties, such as market research and information companies, to create anonymous data, market research, business intelligence or information products which analyze and monitor aggregated location behavior
- To allow third parties to market to you
- When we partner with third parties, such as third party ad or data platforms, to provide the Services to you, or to support, analyze or improve those Services
We may also share your Information with third parties:
- If you request or authorize it
- If the disclosure is done as part of a purchase, transfer, or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, your Personal Information may be one of the transferred assets) or in the event of bankruptcy
- If the information is provided to our third-party vendors or service providers to perform functions on our behalf (e.g., analyzing data, providing marketing assistance, providing customer service, processing orders, etc.)
PRIVACY CHOICES AND OPT-OUT RIGHTS
When we collect location information (generally speaking, lat/long coordinates greater than two decimal places) from mobile app partners, we endeavor to work with partners that provide disclosures to their own users regarding the use of mobile data for location, interest and other user data based advertising purposes, and regarding consumer opt out rights.
You may manage certain collection and sharing of information in connection with the Spoteer Site and the Services as follows:
- You may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser.
- You may limit the disclosure of certain Non-Personal Information by your mobile Device to us and Publishers by adjusting the settings on your mobile Device. For iOS mobile Devices, go to “Settings” from your Device’s home screen; scroll down to “Privacy”; select “Advertising”; and turn on “Limit Ad Tracking.” For Android mobile Devices, go to “Google Settings” on your Device; select “Ads”; and check the box labeled “Opt Out of Interest-Based Ads.”
We honor these “limit” or “opt out” instructions or “flags” by removing recognized Devices from our cross-app advertising or ad delivery and reporting solutions, on a going forward basis. (We may continue to use information from these Devices for other purposes, such as market research and aggregated customer analytics.)
- Publishers and Advertisers may also provide ways for you to opt out from or limit their collection of information from and about you. Please refer to the privacy policies for the Apps to learn more about the privacy practices of Publishers and Advertisers. Please note, however, that we are not responsible for the privacy practices of Publishers, Advertisers, and other third parties.
- You may opt not to receive promotional emails from us by contacting us as indicated be low or by following the “unsubscribe” instructions in any promotional email you receive from us. Please note, however, that we may still send you non-promotional emails about your relationship with us.
DATA ACCESS AND RETENTION
Subject to applicable law and our own rights to retain data, which might, from time to time, oblige us to store your Personal Information for a certain period of time (for instance, for operational or auditing purposes), we will respect your wishes to correct, update or integrate inaccurate information where doing so is feasible and non-burdensome.
You may ask us whether we are storing your Personal Information and for which purposes and in which way we are using your Personal Information, and you may ask to receive a copy of that Personal Information. You may also ask the details of who is in charge of the handling of your Personal Information, and who can access your Personal Information. Before sending you any of your Personal Information, we will ask you to provide proof of your identity. If you are not able to provide proof of your identity, we reserve the right to refuse to send you any Personal Information. You are also entitled to demand the erasure, the anonymization or the block of any Personal Information unlawfully processed.
You may submit us your requests and exercise your rights by contacting us at firstname.lastname@example.org.
We will retain your information for as long as necessary to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We have administrative, technical, and physical safeguards in place in our physical facilities and in our computer systems, databases, and communications networks that are designed to protect information contained within our systems from loss, misuse, or alteration. No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Information and Non-Personal Information.
We encourage End Users to review the privacy policies of Publishers and Advertisers, but we are not responsible for the privacy practices of Publishers, Advertisers, or any third parties.
We may store and process Non-Personal Information in the European Union and the United States. By using an App or Site that uses the Services, you consent to the storing and processing of Non-Personal Information in the European Union and the United States.