Last updated: January 1, 2020
“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”.
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.
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.
(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.
In addition, we use the information collected for our business, including, without limitation, the follow:
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.
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:
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 email@example.com. 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 firstname.lastname@example.org 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 email@example.com.
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.
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.
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.
Placer Labs, Inc.
200 Park Ave.
Santa Cruz, CA 95062
ADDITIONAL NOTICE − EUROPEAN ECONOMIC AREA
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.
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.
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.
SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
Introduction; “Personal Information” under the CCPA
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:
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:
Business or Commercial Purpose Which Personal Information Will Be Used
Sharing of Personal Information
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:
Exercising Your Rights
To request access to your personal information or request deletion, please submit a verifiable request through one of the following methods:
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:
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.
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:
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.
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: