Privacy Policy (Consumers)

Last updated: July 5, 2022

This Privacy Policy describes how Placer Labs, Inc. (“Placer” or “we”) collects, stores, uses and shares information about individuals who use mobile apps developed and operated by third parties that have integrated our software development kit (the “SDK”), from which Placer receives or collects certain information and data (such individuals are referred to herein as “Consumers”).  

This Privacy Policy (Consumers) (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 SDK as a Consumer, 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 SDK.  

  1. WHO ARE “YOU”?

We refer to “you” a lot in this Privacy Policy.  As used in this Privacy Policy, “you” refer to Consumers (as defined above).  

We have a separate privacy policy relating to Placer Customers.  “Placer Customers” means direct users of our Platform Services, and “Platform Services” means (i) the website located at http://placer.ai (the “Site”) and (ii) any services, features, and content downloadable or accessible from the Site.  Categories of Placer Customers may include, among others, (a) developers and operators of mobile apps that have integrated our SDK and (b) 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.  If you are a Placer Customer, please refer to that privacy policy at https://www.placer.ai/privacy-policy/platform-services-privacy-policy/.

  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 identifiers before being sent to Placer to protect the privacy of Consumers. Using aggregated 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 relating to you such as geolocation and proximity data (if you have enabled your device to share location 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 Note about Personally Identifiable Information

The data we receive from any of our location partners, whether “aggregators” or mobile apps that have integrated our SDK, is stripped of identifiers, such as mobile advertising identifiers, names, other persistent device identifiers, and contact information associated with Consumers (hereinafter “User Identifiers”). We intentionally built our Platform Services to produce aggregated market research reports without relying on such User Identifiers.

  1. HOW WE USE THE INFORMATION WE COLLECT

Generally, to provide our Platform Services, we use our proprietary IP and technology to analyze and process the location data collected (free of User Identifiers). We then aggregate that location data and extrapolate the aggregated results so they can be used in our Platform. We then use the extrapolated information (i.e., information not associated with an individual Consumer) to provide certain features of the Platform 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 aggregate Consumer preferences.

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

  • To operate, maintain, enhance, and provide all features of our services; 
  • To improve our services, and to develop new products, services, features, and functionality.  
  1. INFORMATION SHARING

We do not share User Identifiers with any third parties because we do not collect any User Identifiers associated with Consumers. We also do not sell any data about individual Consumers to anyone, nor do we otherwise disclose any data about individual Consumers with anyone except in the limited circumstances described below. As described above, we share only aggregated statistical information with Placer Customers to provide the Platform Services.

We may also disclose information (including information about individual Consumers) under the following circumstances:

  • To Service Providers.  We work with service providers to provide application development, hosting, maintenance, and other services for us. We may transfer, and these service providers 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 our services and any facilities or equipment used to make our 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. 
The use of your information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable information was collected.
  • With Your Consent. We may also disclose your information with your permission.
  1. YOUR CHOICES

You may, of course, decline to share certain information with us.

If you wish to access or amend any information we hold about you, you may contact us at privacy@placer.ai. Please note, however, that because we intentionally do not collect User Identifiers, it is very unlikely that we will be able to associate any information in our systems with you directly. If we are able to locate and associate information in our systems with you, 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. 

  1. THIRD PARTY SERVICES

Our 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

Our services are 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 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 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 Site, 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 our services for the first time after such material changes are made.  Your continued use of the SDK or our 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. 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 privacy@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 SDK.  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 SDK or our 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 for which it is being processed.  For example, we will retain such information for as long as the SDK or our services are active or as needed to provide our 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 our services.  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, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, 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:

CategoryExamplesCollected from Placer Customers
(As “Placer Customers” is defined in our Privacy Policy)
Identifiers.A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.No
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.No
Protected classification characteristics under California or federal law.Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).No
Commercial information.Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.No
Biometric information.Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.No
Internet or similar network activity.Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.No
Geolocation data.Physical location or movements.Yes
Sensory data.Audio, electronic, visual, thermal, olfactory, or similar information.No
Professional or employment- related information.Current or past job history or performance evaluations.No
Non-public education information (as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99).Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.No
Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99).grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Inferences drawn from other personal information.Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.Yes

Categories of Sources from Which Personal Information is Collected

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

  • mobile apps that have integrated our SDK (as described in Section 3.1 of the Privacy Policy).

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 information (i.e., non-personal information) to provide certain features of the Platform 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 our services.

Sharing of Personal Information

As described in more detail 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 require 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; or 
  • Toll-free number:  +1 (888) 383 3424

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 usable 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:

  • Email:  privacy@placer.ai; or
  • Toll-free number: +1 (818) 937-0444
  • Mailing address:  Placer Labs, Inc., 340 S Lemon Ave, #1277, Walnut, CA 91789, USA

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