Last updated: December 15, 2020
- WHO ARE “YOU”?
- 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.
- 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), 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 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.
- HOW WE USE THE INFORMATION WE COLLECT
- 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:
- To operate, maintain, enhance, and provide all features of our services;
- To provide support to our users;
- To understand and analyze the usage trends of our users;
- To improve our services, and to develop new products, services, features, and functionality.
- INFORMATION SHARING
We may share non-PII with Placer Customers to provide the Platform 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 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.
- 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 SDK or our services.
If you wish to access or amend any other PII we hold about you, you may contact us at firstname.lastname@example.org. 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 email@example.com 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, you will continue to receive administrative messages from us regarding our 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 firstname.lastname@example.org.
- 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.
- 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.
- 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.
- INTERNATIONAL TRANSFER
- EUROPEAN ECONOMIC AREA AND CALIFORNIA APPENDICES
- DISPUTE RESOLUTION
- HOW TO CONTACT US
Placer Labs, Inc.
340 S. Lemon Ave. #1277
Walnut, CA 91789
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 SDK or our 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 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.
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:
- 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:
|Category||Examples||Collected from Placer Customers|
|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.||Yes (Internet Protocol address and device identifier only)|
|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 (40 years or older), 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.||Yes|
|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:
Business or Commercial Purpose Which Personal Information Will Be Used
- We use the aggregated and anonymized 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.
- We may also use your email address, if we have one on file, or other information to contact you for administrative or customer service purposes, and to send other business communications to you.
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:
- 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: email@example.com; 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 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:
- 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.
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: firstname.lastname@example.org; or
- Toll-free number: +1 (818) 937-0444
- Mailing address: Placer Labs, Inc., 340 S Lemon Ave, #1277, Walnut, CA 91789, USA