Privacy Policy

Last updated:  January 1, 2020

This Privacy Policy describes how Placer Labs, Inc.  (“Placer” or “we”) collects, stores, uses and shares information about users of our Services.  Our “Services” means (i) the website located at http://placer.ai (the “Site”), (ii) any services, features, and content downloadable or accessible from the Site (for example, and without limitation, when you log in to your Account via the Site), (iii) the Placer software development kit (the “SDK”), and (iv) any other Placer application, software, product, or service licensed, downloaded or otherwise accessed by you, whether through Placer or third party websites or sources.

This Privacy Policy (this “Privacy Policy”) is incorporated into and is subject to our Terms of Use at https://placer.ai/terms-of-service (the “Terms of Use”).  By using the Services, you agree to Placer’s collection, storage, use and disclosure of your information as described in this Privacy Policy.  If you disagree with anything in this Privacy Policy, please do not use the Services.

  1. WHO ARE “YOU”?

We refer to “you” a lot in this Privacy Policy.  To better understand what information is most relevant to you, please see the following definitions:

Consumers” means individuals who use mobile apps from which Placer receives or collects information and data in connection with the Services.  These mobile apps are developed and operated by third parties that have integrated our SDK.

Placer Customers” means direct users of Placer’s Services.  Categories of Placer Customers may include, among others, (i) developers and operators of mobile apps that have integrated our SDK and (ii) users of our data analytics without integrating the SDK.  Placer Customers’ may be retail stores, restaurants, brands, researchers, and advertising agencies, just to name a few examples. Users of the Site are also Placer Customers.

Depending on your relationship with us, you may be both a “Consumer” and “Placer Customer”.

  1. HOW DOES PLACER WORK?

Placer’s technology is deployed, via integration of our SDK, in thousands of mobile apps and millions of devices.  Placer’s technology collects data, such as geolocation data, which is scrubbed of any personally identifiable information to protect the privacy of Consumers.  Using the aggregated and anonymized data, Placer provides data analytics and actionable insights to Placer Customers. Such data analytics and actionable insights may include foot traffic patterns and Consumer preferences, among many other examples.

  1. INFORMATION WE COLLECT

3.1 From Consumers

If you are a Consumer, we may collect information such as geolocation and proximity data (if you have enabled your device to share location information), IP address, unique device identifiers for advertising (Google Advertiser ID or IDFA) and/or a pixel identifier, event information about your device (such as crashes, system activity, and hardware settings), system configuration information, time and date information, and dwell time near points of interest, as determined through beacon, Wi-Fi, and other signals per our proprietary systems.  Generally, the information we collect is not information that identifies you personally. We receive such data from mobile apps that have integrated our SDK. We rely upon the developer and operator of these mobile apps to enable your connection to our Services to provide or withdraw consent with respect to the collection and use of your information. You may also control your mobile device directly by enabling or disabling the applicable settings, such as your location settings.

3.2 From Placer Customers

If you are a Placer Customer, we may receive (a) information provided by you and (b) information that is automatically collected.

(a) When you use the Services, we may collect information that you provide, including your name, your company name, email address, mailing address, billing and payment information, your preferences, and your customer data, among other things.  You may provide us with information in various ways on the Services, such as when you register for an account, pay for the Services, send us customer service questions or support requests, or when you upload your customer data. (Additional terms and conditions governing your upload of customer data are set forth in the Terms of Use.)

(b) When you use the Services, we may also automatically collect other information about you, such as IP address, browser type, domain names, referring website addresses, access times, web log data, and other event information.  Such automatic collection of information may be enabled by cookies, pixels, or other tools. Please refer to the settings for your device, web browser, and operating system for more information on how to disable such tools and control your preferences.

3.3 Note about Personally Identifiable Information

“Personally Identifiable Information”, as the term is used in the United States, or “Personal Data” as referred to for individuals pursuant to the European Directives 95/46/EC and 2002/58/EC (EU General Data Protection Regulations Legislation, also known as GDPR) (hereinafter “PII”), is information used or intended to be used to identify a particular individual.  We strive to only collect PII if you voluntarily provide it to us or the applicable Placer Customers by your consent, such as information you provide when completing a registration form, information you publicly share over social media, and other information you make available based on your privacy settings on third party apps and services and by your consents.

  1. HOW WE USE THE INFORMATION WE COLLECT

First of all, we do not share PII with any third parties, unless explicitly permitted in this Privacy Policy or with your consent.  Generally, to provide our Services, we use our proprietary tools to analyze and manipulate the data collected, such as geolocation information, and the data is scrubbed of PII.  With respect to device identifiers for advertising, for example, we hash all device identifiers information after collection so as to not retain PII. We then use the aggregated and anonymized information (i.e., non-PII) to provide certain features of the Services, including, without limitation, the following:

  • To provide Placer Customers with visibility into Consumer foot-traffic;
  • To provide Placer Customers with insight into different venues and places;
  • To analyze Consumer preferences; and
  • To attribute Consumers’ visits to stores or other specific points of interest for advertising campaigns.

In addition, we use the information collected for our business, including, without limitation, the follow:

  • To operate, maintain, enhance, and provide all features of the Services;
  • To provide support to Placer Customers;
  • To understand and analyze the usage trends of Placer Customers;
  • To improve the Services, and to develop new products, services, features, and functionality.

If you are a Placer Customer, we may also use your email address or other information to contact you for administrative or customer service purposes, and to send other business communications to you, such as updates about our Services.

  1. INFORMATION SHARING

We may share non-PII with Placer Customers to provide the Services, as described above.

We may also disclose information (including PII) under the following circumstances:

  • To Service Providers.  We work with third party service providers to provide application development, hosting, maintenance, and other services for us.  We may transfer, and these third parties may have access to or process, information about you as part of providing those services for us.  Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information.
  • To Comply with Laws.  We may disclose information about you if required to do so by law or in the good-faith belief that such action is necessary to comply with laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
  • To Protect Our Legal Rights.  We also reserve the right to disclose information about you that we believe, in good faith, is appropriate or necessary to: (i) take precautions against liability; (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity; (iii) investigate and defend ourselves against any third party claims or allegations; (iv) protect the security or integrity of the Services and any facilities or equipment used to make the Services available; or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.
  • In Corporate Reorganizations.  Information may be disclosed during due diligence or in preparation for or after an acquisition or merger, consolidation, change in control, transfer of substantial assets, financing, reorganization or similar corporate transactions with requirements for the receiving party to maintain the confidentiality of such information, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
  1. YOUR CHOICES

You may, of course, decline to share certain information with us, in which case we may not be able to provide to you some of the features and functionality of the Services.

If you wish to access or amend any other PII we hold about you, you may contact us at info@placer.ai.  Please note that while any changes you make will be reflected in our databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

If you receive commercial email (e.g., promotions) from us, you may unsubscribe at any time by following the instructions contained within the email.  You may also opt out from receiving commercial email from us by sending your request to us at info@placer.ai or by writing to us at the address at the end of this Private Policy.  Please be aware that it may take up to ten (10) business days for us to process your request, and you may continue to receive commercial email from us during that period. Additionally, even after opting out from receiving commercial email from us, Placer Customers will continue to receive administrative messages from us regarding the Services.

Under California law, California residents who have an established business relationship with us may choose to opt out of the disclosure of PII about them to third parties for such third parties’ direct marketing purposes.  Our policy is not to disclose PII collected online to any third party for direct marketing purposes without your approval. If you choose to opt-out at any time after granting approval, please email info@placer.ai.

  1. THIRD PARTY SERVICES

The Services may be integrated with, or contain features or links to, mobile apps and services provided by third parties.  Any information you provide on third party mobile apps and services is provided directly to the operators of such mobile apps and services and is subject to those operators’ policies, if any, governing privacy and security.  We are not responsible for the content or privacy and security practices and policies of such third parties. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

  1. DATA SECURITY

We use certain physical, managerial, and technical safeguards that are designed to improve the integrity and security of information that we collect and maintain.  Please be aware that no security measures are perfect or impenetrable. We cannot and do not guarantee that information about you will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

  1. CHILDREN’S PRIVACY

The Services is not directed to children under the age of 13.  We do not knowingly collect any information at all from children under the age of 13.

  1. INTERNATIONAL TRANSFER

We may transfer information that we collect about you to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world.  If you are located in the European Economic Area (EEA) or other regions with laws governing data collection and use that may differ from U.S. laws, please note that you are transferring information, including PII, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S.  and the use and disclosure of information about you, including PII, as described in this Privacy Policy.

  1. EUROPEAN ECONOMIC AREA AND CALIFORNIA APPENDICES

If you are located in the European Economic Area (EEA), please further see Appendix A at the end of this Privacy Policy.  If you are a California resident, please further see Appendix B at the end of this Privacy Policy.

  1. CHANGES AND UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time.  Please revisit this Privacy Policy periodically to stay aware of any changes.  If we modify this Privacy Policy, we will make it available through the Services, and indicate the date of the latest revision.  In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change.  For example, we may send a message to your email address if we have one on file, or generate a pop-up or similar notification when you access the Services for the first time after such material changes are made.  Your continued use of the Services after the revised Privacy Policy has become effective indicates that you have read, understood and agreed to the latest version of this Privacy Policy.

  1. DISPUTE RESOLUTION

This Privacy Policy shall be governed by the laws of the State of California without regard to conflict of laws provisions.  Any dispute, claim or controversy arising out of or relating to this Privacy Policy shall be subject to the dispute resolution provisions in our Terms of Use.

  1. HOW TO CONTACT US

Please contact us with any questions or comments about this Privacy Policy, information we have collected or otherwise obtained about you, our use and disclosure practices, or your consent choices by email to info@placer.ai or by physical mail to:

Placer Labs, Inc.

340 S. Lemon Ave. #1277

Walnut, CA 91789

USA



APPENDIX A

ADDITIONAL NOTICE EUROPEAN ECONOMIC AREA 

Your Rights

We respect your privacy rights and provide you with reasonable access and rights to the Personal Data, as this term is referred to for individuals located in the European Economic Area (EEA), pursuant to the European Directives 95/46/EC and 2002/58/EC (EU General Data Protection Regulations Legislation, also known as GDPR), that you may have provided through your use of the Services.  If you live in one of those countries, and wish to access, amend, delete, or transfer any Personal Data we hold about you, you may contact us as set forth in the “How to Contact Us” section in the Privacy Policy.

You may update, correct, or delete your Personal Data and preferences at any time by request to us.  Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

You may decline to share certain Personal Data with us, in which case we may not be able to provide to you some of the features and functionality of the Services.

At any time, you may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law.  If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact us as set forth in the “How to Contact Us” section in the Privacy Policy.  You also have a right to lodge a complaint with data protection authorities.

Legal Basis for Processing Personal Data; Retention

Placer will only collect and process Personal Data when we have lawful bases for doing so.  These lawful bases include when you provide consent, when we have a contractual obligation to collect or process your Personal Data, and when we have a legitimate interest in processing your Personal Data.

When we collect Personal Data, we keep it for as long as we need it for the purpose it is being processed for.  For example, we will retain your email information for as long as the Services are active or as needed to provide the Services to you.  After that, we will keep the Personal Data for a period which enables us to handle or respond to any complaints, queries or concerns relating to your use of the Products.  We retain the identifiable data we collect directly for targeting purposes for as little time as possible, after which we employ measures to permanently delete or anonymize or de-identify the data.  We will periodically review the Personal Data we hold and delete it securely when there is no longer a legal, business, or consumer need for it to be retained.

Transfers

Where we transfer your Personal Data outside the EEA, we rely on approved standard EEA Model Clauses so these transfers are conducted in accordance with applicable laws and using adequate and appropriate safeguards.



APPENDIX B

SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

Introduction; “Personal Information” under the CCPA

This Appendix B supplements the information contained in our Privacy Policy above and applies solely to those of you who reside in the State of California.  We adopt this supplemental notice to comply with the California Consumer Privacy Act of 2018 (the “CCPA”).  Any terms defined in the CCPA have the same meaning when used in this Appendix B, unless otherwise noted.

Under the CCPA, “personal information” is information that identifies, relates to, describes, or is capable of being associated with a particular consumer or household.  Personal information does not include:

  • Publicly available information;
  • Deidentified or aggregated consumer information; or
  • Information excluded from the CCPA’s scope, such as:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 and the California Confidentiality of Medical Information Act or clinical trial data; or
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act, the GrammLeach-Bliley Act or California Financial Information Privacy Act, and the Driver’s Privacy Protection Act of 1994.

Information We Collect

The table below sets forth the categories of personal information that we have collected within the last twelve (12) months:

Categories of Sources from Which Personal Information is Collected

We obtain the personal information listed above from the following categories of sources:

  • with respect to Consumers, from mobile apps that have integrated our SDK (as described in Section 3.1 of the Privacy Policy);
  • with respect to Placer Customers:
    • directly from you (as described in Section 3.2(a) of the Privacy Policy, such as, without limitation, when you register for an account); and
    • automatically when you interact with our Services (as described in Section 3.2(b), such as, without limitation, as enabled by cookies, pixels, or other tools).

Business or Commercial Purpose Which Personal Information Will Be Used

First of all, we do not share personal information with any third parties, unless explicitly permitted in our Privacy Policy or with your consent.

As described in more details in Section 4 of our Privacy Policy:

  • We use the aggregated and anonymized information (i.e., non-personal information) to provide certain features of the Services, including, without limitation, to provide Placer Customers with visibility into Consumer foot-traffic.
  • In addition, we use the information collected for our business, including, without limitation, to operate, maintain, enhance, and provide the features of the Services.
  • If you are a Placer Customer, we may also use your email address or other information to contact you for administrative or customer service purposes, and to send other business communications to you.

Sharing of Personal Information

As described in more details in Section 5 of our Privacy Policy, we may share personal information with third-party service providers, to comply with laws, to protect our legal rights, and in corporate reorganizations.  When appropriate, we enter into contracts with third parties that describe the purpose of the disclosure and requires the recipient to keep that personal information confidential.

No Sale of Personal Information

We do not sell personal information to third parties.  As used here, to “sell” means to disclose personal information to third parties for monetary or other valuable consideration, but does not include, for example, the transfer of personal information as an asset that is part of a merger or other disposition of all or any portion of our business.

Rights under the CCPA

Access to Specific Information; Deletion

If you are a California resident, you have the right to:

  • Request that we disclose to you the following information covering the 12 months preceding your request:
    • the categories of personal information that we have collected about you;
    • the categories of sources from which the personal information was collected;
    • the business or commercial purpose for collecting personal information about you;
    • the categories of third parties to whom we disclosed personal information about you, the categories of personal information that was disclosed, and the purpose for disclosing the personal information about you (if we have made any such disclosures); and
    • the specific pieces of personal information we collected about you; and
  • Request that we delete personal information we collected from you, unless the CCPA recognizes an exception.

Exercising Your Rights

To request access to your personal information or request deletion, please submit a verifiable request through one of the following methods:

  • Email:  privacy@placer.ai
  • Toll-free phone number for privacy-related questions:  +1 (978) 800-0427
     

Only you or a person authorized to act on your behalf may make a consumer request related to your personal information.

You may only request a copy of your data twice within any 12-month period.  The request must:

  • Provide sufficient information to allow us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
  • Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

Our goal is to respond to a verifiable request within 45 days of its receipt.  If we require more time, we will inform you of the reason and extension period in writing.  Any disclosures we provide will cover only the 12-month period preceding the request. If applicable, the response we provide will also explain the reasons we cannot comply with the request.  We will provide your personal information in a format that is readily useable and should allow you to transmit the information without hindrance.

We will not charge a fee to process or respond to your request unless it is excessive or repetitive.  If we determine that the request warrants a fee, we will provide you with the basis for that decision and a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your rights under the CCPA.  Unless permitted by the CCPA, we will not, because of your exercise of such rights:

  • Deny you goods or services;
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
  • Provide you a different level or quality of goods or services; or
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time.  When we make changes to this privacy notice, we will notify you by email or through a notice on our website.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at:

  • privacy@placer.ai
  • +1 (978) 800-0427 — toll-free number for privacy-related questions
  • Placer Labs Inc., 340 S. Lemon Ave., #1277, Walnut, CA 91789, USA

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