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Privacy Policy

Effective: April 5, 2020

 

Point Inside, Inc. ("Point Inside”, "we”, "us”, or "our”), the builder of the Point Inside platform, is committed to protecting your privacy. We know that you care about how information about you is used and shared, and we appreciate your trust that we will use that information carefully and sensibly in accordance with this Privacy Policy.

Please read this Privacy Policy carefully so that you understand our privacy practices. This Privacy Policy governs the personally identifiable information ("Personal Information” or “PII”) collected by Point Inside through our web SDKs, web APIs, and website at PointInside.com (the "Website”) and through mobile applications using the Point Inside mobile SDK (the "Mobile Product”). Except as specifically set forth below, the terms of this Privacy Policy apply to the Websites and our Mobile Products.

By visiting our Websites, you agree to the terms of this Privacy Policy with respect to your use of our Websites and any Personal Information that you may provide to us through the Website. If you are using one of our Mobile Products, whether provided directly by Point Inside or by one of our content partners ("Publishers”), your use of the Mobile Product will be governed by the terms of this Privacy Policy. This Privacy Policy will govern our collection, sharing, use, and security of your Personal Information and Non-directly identifying Personal Information. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information. If you do not agree to the terms of this Privacy Policy, you should not install the Mobile Product and/or should uninstall the Mobile Product immediately. Your use of the Mobile Product shall constitute your acceptance of the terms of this Privacy Policy.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Point Inside is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Point Inside may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

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Trusted Partners

 

Trusted Partners are third party companies that have partnered with Point Inside.

  • Our Trusted Partners may include brands, data platforms, online advertising networks, and companies that perform research about consumer behavior, targeted or customized advertising, or human traffic patterns.

  • Our Trusted Partners may share Precise and Geographic Location Data with us such as browser cookie IDs, mobile device IDs, IP address, device type, operating system, hashed email address, or hashed mobile ID (e.g., Apple IDFA or Android advertising ID), as well as location-based data such as Wi-Fi, cell tower, GPS or diagnostic location information, contextual information, and demographic information including age, gender and zip code.

  • Point Inside may receive Precise and Geographic Location Data from third-party partners including Cuebiq and Reveal Mobile.

 

Privacy of Children

 

Protecting the privacy of children is especially important. For that reason, Point Inside does not knowingly collect any Personal Information from anyone under the age of 13. In no other way do we knowingly collect or maintain personally identifiable information from persons under 13 years of age, and no part of our Website is directed to persons under 13. If Point Inside learns that Personal Information of persons under 13 years of age has been collected through its Website or a Mobile Product, then Point Inside will take the appropriate steps to delete this information.

 

Information Collection and Use

 

Website

Point Inside collects data from our websites and applications as follows:

  • Information you provide: You are not required to register or actively provide any Personal Information in order to browse our Website and learn more about our company, our products and our technology. We may actively collect Personal Information from you when you voluntarily provide it to us, and it is needed to provide you a service. For example, we will collect your email address if you provide it and want to subscribe to our newsletter.

  • Browser-Level Information: When you browse our Website or use any of our Mobile Products, our web server automatically collects limited information about your computer configuration or device or, such as the type of browser software you use and the operating system you’re running and your IP address.

  • Non-directly identifying Personal Information: Point Inside does log these types of information which may include IP address, profile information, browser type, browser language, referring / exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, from users and visitors to the Website and the type of mobile device you use, the IP address of your mobile device, your mobile operating system, and the type of mobile browsers you use. This data is used to manage our Website, including diagnosing problems with our Website, track usage and improve the Website. User IP addresses are recorded for security and monitoring purposes.

  • Use of Cookies: Cookies are small files placed on your computer’s hard drive by a website when you visit. These files identify your computer and record your preferences and other data about your visit so that when you return to the site, the site knows who you are and can personalize your visit. For example, cookies enable a Web site shopping cart to function so that you only have to check out once. Consequently, cookies are often tied to the use of personally identifiable information while using our site, and some functionality may be lost if you choose not to accept the use of cookies. In general, we use cookies to collect information so that we can determine how to improve our site by seeing which areas and features are most popular; to personalize the site; and to complete transactions you have requested. We also use a session-based cookie that maintains a user’s session for continuity of navigation while viewing the site. After closing the browser, the session cookie simply terminates. Depending on the phone or device being used, cookies may be stored locally on the phone or device, or on servers operated by Point Inside. This Internet cookie-like functionality is in place for the same reasons and designed for the same purposes as cookies placed on your computer when interacting with Internet Web sites.

  • Use of Web Beacons: A Web beacon, also known as a Web bug, is a small, graphic image on a Web page, Web-based document or in an email message that is designed to allow the site owner or a third party to monitor the address and other information of the computer viewing the item. Web beacons are often invisible to the user because they are typically very small (only 1-by-1 pixel) and the same color as the background of the Web page, document, or email message. Web beacons are represented as HTML IMG tags in the Web page; users can click on view profiles of the Web page to see whether the page is using a Web beacon. Web beacons collect the IP address of the computer that the Web beacon is sent to, the URL of the page the Web beacon comes from, and the time it was viewed. Web beacons can also be linked to personal information. Point Inside does not place Web beacons that link to personal information on other sites, nor does it permit third parties, other than those working on our behalf, to place them on our site. Point Inside does use Web beacons itself and may link a particular beacon to personal information. For example, we may use a beacon to ensure a user can flip between technical assistance, customer service and our online store and still be recognized as our customer.

Mobile Products

Point Inside provides SDKs for each of the Android and iOS mobile operating systems (the "SDKs" or "Mobile Products") which collect data about mobile devices. These Mobile Products are often used via a Publisher’s own mobile properties, which act as a host for the Mobile Products. As such, use of the Mobile Products may come "indirectly" via use of a Publisher’s own mobile product. This Privacy Policy does not govern the use by a Publisher of any Personal Information you may provide to the Publisher through our Mobile Product, the Publisher’s mobile product, or otherwise. Before sharing Personal Information with any Publisher, you should review the privacy policy of the Publisher.

  • Personally Identifiable Information: We do not store Personal Information through our Mobile Products.

  • Automatically Collected Information: Other Non-directly identifying Personal Information When you use any of our Mobile Products, we automatically collect limited information about your computer configuration or device, such as the operating system the device is running and its IP address. Point Inside does log non-directly identifying Personal Information which may include IP address, profile information, browser type, browser language, platform type, domain names, the type of mobile device you use, the IP address of your mobile device, your mobile operating system, identifierForVendor and the type of mobile browsers you use. This data is used to manage the Mobile Product, including diagnosing problems with the Mobile Product, track usage, and improve the Mobile Product.

  • Mobile Advertising Identifiers: Both the Android and iOS mobile operating systems provide transient, resettable, and unique identifiers for the purposes of advertising; these are known as the Android Advertising ID and the Apple Identifier for Advertising (IDFA). Both identifiers have policies governing appropriate use, which the Mobile Products respect. The most important aspect of acceptable use of identifiers is respecting your ability to opt-out of its use. Point Inside collects these identifiers whenever the Mobile Products communicate with our server, if you have allowed your device to use these identifiers. These identifiers are considered to be non-directly identifying, can be reset and are randomly generated.

  • Location Data: By opting in to share your location data, the Mobile Product also allows us to collect information regarding your location, or the location of your device, by using GPS coordinates provided by your mobile device, or if you come within proximity of a Bluetooth Low Energy (BLE) device such as a beacon ("Location Data”). When any of our Mobile Products is open on your mobile device, we periodically receive Location Data. Most GPS-enabled mobile devices can identify a user’s location to within less than 50 feet. You can opt-out of our collection of such Location Data by turning off the GPS capability of your mobile device and rejecting our request to collect such data upon installation of the Mobile Product. If following installation of the Mobile Product, you wish to opt out of the collection of Location Data, you can change the preferences on your mobile device (by turning off the GPS capability for the Mobile Product) or by uninstalling the Mobile Product. If you choose not to permit the Mobile Product to collect such Location Data, certain of the Publisher’s services may not be available to you. Point Inside stores Location Data, and Location Data is passed through to the service providers and partners, including ad networks, ad serving companies and third-party information providers, as described below.

  • Aggregate Information Used to Serve and Target Ads: We may aggregate the information we collect from users of our Mobile Products and use this to target ads on digital out-of-home screens. Additionally, we may use information we collect from users of our Mobile Products to obtain consumer data (Third Party Data) from third parties (Third Party Data Providers); this is described in the next section. When we aggregate your information, no directly identifying personal information is included.

  • Aggregate Information Used for Location Analytics: We may aggregate the information we collect from users of our Mobile Products and Third-Party Data for reporting and analytics purposes. This is the same data we use to serve and target advertising and follows the same restrictions and guidelines. Location Analytics refers to the process of aggregating, packaging, and visualizing this data for particular physical locations.

  • Mobile Analytics: We use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.

  • Opt-Out of Information Collection: You can stop all collection of information by emailing optout@pointinside.com.

Point Inside collects information under the direction of the Publishers and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Publishers and would no longer like to be contacted by one of our Publishers that use our service, please contact the Publishers that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Publishers.

An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to the Point Inside Publisher (the data controller). If requested to remove data, we will respond within a reasonable timeframe.

We will retain personal data we process on behalf of the Publishers for up to ten years to provide services to the Publishers. Point Inside will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

 

Disclosure and Sharing of Information

 

Information about our customers is an important part of our business. We will share your personal information with third parties only in the ways that are described in this privacy policy. We share your personal information with other companies so that they can market their products or services to you. If you do not want us to share your personal information with these companies, contact us at privacy@pointinside.com

  • We may disclose your personal information to our service providers who work on behalf of Point Inside, including to provide our Website or the Mobile Product or fulfill user requests such as demographics databases. However, these companies are not allowed to share this information or to use it for their own purposes. These companies are authorized to use your personal information only as necessary to provide these services to us.

  • We may disclose your Mobile Advertising Identifiers to Third Party Data Providers for the purposes of acquiring additional consumer data. The Mobile Advertising Identifier acts as an index that can be used across datasets, similar to how cookies are utilized. These Third Parties have their own privacy policies that govern the use of the data they collect, which we do not control.

  • We may disclose your Location Data to third parties for the purposes of providing targeted advertisements and information our advertising partners believe may be of relevance and interest to you; these third parties include but are not limited to ad networks and ad serving companies. Advertising helps us provide the Mobile Product and helps our Publishers provide free services and content. You can opt-out of our collection of such Location Data by turning off the GPS capability of your mobile device and rejecting the request to collect such data upon installation of the Mobile Product or by emailing the Publisher to request opt-out on collecting such information.

  • In accordance with the practices as governed by the Publisher’s privacy policy, we may sell your Location Data to third parties, such as data marketplaces, at the request of the Publisher, in order to supplement the Publisher’s revenues.

  • We may disclose your Data to third parties to provide you with targeted information as requested by you. For example, we will provide your Location Data to a third-party partner so that they can provide you with location specific advertising.

  • We may disclose your Non-directly identifying Personal Information, which may include your IP address and as part of an aggregate data set to third parties for the purposes of providing targeted advertisements and information our advertising partners believe may be of relevance and interest to you.

  • We may disclose your personal information to lawful requests by public authorities, including to meet national security or law enforcement requirements, to comply with legal requirements or to respond to a subpoena, search warrant or other legal process or government request received by Point Inside, whether or not a response is required by applicable law.

  • We may disclose your personal information to enforce our rights in our Website and Mobile Products or to protect the rights, property or safety of members of the Point Inside community, our Publishers, other visitors to our Mobile Products, the public, or Point Inside and its employees.

  • From time to time you may be able to participate in contests, giveaways, or other similar promotions we sponsor. Except as explained otherwise in the rules for a particular contest, giveaway, or promotion, any personal information you provide will be used in accordance with this Policy.

  • As our business grows, we may buy or sell various assets. In the event that Point Inside or some or all of our assets are acquired by another company, our users’€™ personal information may be among the transferred assets. You will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. We may also disclose your personal information to any other third party with your prior consent.

  • In the event that Point Inside goes through a bankruptcy, reorganization, receivership or similar event, you understand and agree that we may not be able to control how your personal information collected by us is treated, transferred or used.

 

General Data Protection Regulation (GDPR)

 

As of May 25, 2018, the EU General Data Protection Regulation (GDPR) went into effect through the EEA countries and Switzerland. The GDPR requires that companies provide users with certain information about the processing of their “Personal Data” “Personal Data” is a term used in Europe that means, generally, data that identifies or can identify a particular unique user or natural “persona” for instance, names, addresses, cookie identifiers, mobile device identifiers, precise location data and biometric data.

To comply with GDPR, we provide the below representations and information, which are specific to persons located in EEA countries or Switzerland (so please do not rely on the below, if you’re not):

a. Legal grounds for processing your Personal Data

GDPR requires us to tell you about the legal basis we’re relying on to process any Personal Data about you. The legal basis for us processing your Personal Data for the purposes set out in the section entitled Information Collection and Use will typically be because:

  • You provided your consent. In order to provide our services that involve use of precise location information related to other Personal Data, (and to store and gain access to information stored on your device such as Device IDs), we rely on your consent. To obtain this consent, we rely on our own compliance steps and our web and mobile partners’ compliance steps, designed to ensure that consent is collected and passed on to partners, and to ensure that we only facilitate the collection of legally obtained data. We may choose to obtain consent in other cases as well, in which case we will adhere to applicable laws relating to such consent and its withdrawal. We also seek to obtain consent for certain partners with whom we work, who are often independent data controllers.

  • The processing is in our legitimate interest. In some cases, we use legitimate interest as a legal basis for processing Personal Data. We rely on legitimate interest when we use Personal Data to maintain the security of our services, such as to detect fraud or to ensure that bugs are detected and fixed. We also rely on legitimate interest when we use our own customers’ data (or Visitors’ data) to communicate with them about our Services or analyze our own Site activity.

  • Contractual Relationships. Sometimes, we process certain data as necessary under a contractual relationship we have (such as our customer records and contact information);

  • Legal Obligations. Finally, some processing of data may be necessary for us to comply with our legal or regulatory obligations.

b. Transfers of Personal Data

When we transfer Personal Data outside of the EEA or Switzerland, we take steps to make sure that appropriate safeguards are in place to protect your Personal Data. In general, our data transfers of our Personal Data are safeguarded by mechanisms such as Privacy Shield, European Standard Contractual Clauses, and Data Processing Agreements where this is required by European Data Protection Law. Feel free to contact us at the contact information below for more information about the safeguards we have put in place to protect your Personal Data and privacy rights in these circumstances.

As Point Inside works with global companies and technologies, we may need to transfer your Personal Data outside of the country from which it was originally provided. For instance, we may transfer your data to third parties that we work with who may be located in jurisdictions outside the EEA or Switzerland, and which have no data protection laws or laws that are less strict compared with those in Europe.

c. Personal Data Retention

As a general matter, we retain your Personal Data for up to ten years to provide our Services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements. Please note that we may retain this (and other) Information whenever and so long as we have a significant legal or operational need to do so, such as for auditing, corporate record-keeping, compliance accounting or security and bug-prevention purposes.

If you are a customer of ours and thus have an account with us, we will typically retain your Personal Data for up to ten years in order to serve the purpose for which it was collected, such as to provide you relevant information about our products and services.

d. Your Rights as a Data Subject

The GDPR provides you with certain rights in respect of Personal Data that data controllers hold about you, including certain rights to access Personal Data, to request correction of the Personal Data, to request to restrict or delete Personal Data, and to object to our processing of your Personal Data (including profiling for online ad targeting).

  • Right to Access: If you wish to exercise your right to access Personal Data we process as a data controller, you may do so by requesting access through the e-mail address privacy@pointinside.com. When we receive your request, we will provide you with current, step-by-step instructions to follow in order to obtain access. As we are required to verify a requestor’s identity prior to providing Personal Data, we will assess requests to exercise certain data access rights on a case-by-case basis: in doing so, we consider (a) the difficulty of verifying whether data that we hold and data we have linked to it truly and solely belongs to the data subject making the request, along with (b) the potential adverse effects on disclosure of personal data to the wrong individual. Because such improper disclosure would likely adversely affect the privacy rights and freedoms of the data subject, we may limit the Personal Data we make available. Please note that we will only grant requests for access for Personal Data for which we are a data controller, as explained further in sub-section (e) below. Where we act as a processor for one of our customers, we will refer your request to that customer. Please identify the customer your request refers to (if possible), to simplify this process.

  • Right to Correct: If you wish to exercise your right to correct Personal Data, you may do so by contacting us at the contact information below.

  • Right to Object to Processing or to Withdraw Consent: By using the device-based “opt-out” signals described in this Privacy Policy, you may withdraw consent for processing on which we rely on consent. If you do so, we will cease processing your Personal Data for purposes of our services within 30 days. We either collect these opt-out signals ourselves or receive them from the mobile apps we work with.

  • Right to Erasure. You also have the right to obtain the erasure of Personal Data concerning you that we hold as a controller. The above opt-out process satisfies this right. When a user opts-out through our partners (or through mobile device settings), and we receive this signal, we no longer use Personal Data to provide our advertising services. We will also manually delete your Personal Data if you prefer that we do so; please contact us and email your device to privacy@pointinside.com for further instructions if you wish to exercise this right manually. Please note, however, that we may retain copies of certain Personal Data on inactive or back-up files, for our certain important internal and purposes, such as auditing, accounting and billing, legal or bug-detection, for as long as is necessary to fulfill those purposes.

  • Right to Lodge Complaints. You have the right to lodge a complaint with a supervisory authority. However, we hope that you will first consult with us, so that we may work with you to resolve any complaint or concern you might have.

e. Point Inside as a data controller and a data processor

EU data protection law makes a distinction between organizations that process Personal Data for their own purposes (known as “data controllers”) and organizations that process Personal Data on behalf of other organizations (known as “data processors”). As noted above, we are not always a data controller of the data in our possession but are sometimes a data processor for other companies such as our customers. In such cases, we may direct your inquiry to the relevant data controller, since data controllers are the ones with primary responsibility for your Personal Data.

 

California Customers

 

Point Inside does not disclose customers’ personal information to third parties for the third parties direct marketing purposes, as governed by California Civil Code 1798.83.

 

Other Information

 

Access and Choice

Upon request Point Inside will provide you with information about whether we hold or process on behalf of a third party, any of your personal information. To request this information please contact us at privacy@pointinside.com.

If you wish to request access, or deletion of your personal information please contact us at privacy@pointinside.com. We will respond to your request within a reasonable timeframe.

Opt-Out

If you provide Personal Information to us through our Website, such as signing-up for our newsletter, you may request that we delete such Personal Information from our system, by sending a request to optout@pointinside.com, or by choosing the limit ad tracking setting on your device’s privacy settings page. We will promptly cease use of any such Personal Information and will remove such Personal Information from our servers in accordance with our standard practices. Certain other components of your Data relating to your use of the Website or Mobile Products, such as Mobile Advertising Identifiers, may be retained for up to ten years in order to serve the purpose for which it was collected.

Reset an Advertising Identifier

Resetting an advertising identifier is very easy on both iOS and Android (step-by-step guide below):

  • iOS: Go to Settings > Privacy > Reset Advertising Identifier and then Reset Identifier when the prompt comes up.

  • Android: Go to Settings > Google > Ads > Reset Advertising ID and click OK when the confirmation screen appears.

Social Media Sites, Links to Other Sites

We may have pages, accounts or presence on various social networking and media sites or services, such as Facebook and Twitter. Social media buttons or interactive mini programs that run on our website may collect your Internet protocol address, which page you are visiting on our website, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our website. Any information you post or provide through such social media sites and services will be subject to the policies of the applicable site or service.

The Website and Mobile Products may include advertisements and links to third-parties websites or service whose privacy policies we do not control. When you access another app or site, use of any information you provide on such site or app, and any information collected by the site operator, is governed by the privacy policy of the operator of the app or site you’re visiting. If you click through to any of the advertisers on a Mobile Product, the advertiser may also track your device. We do not have access to or control any information they may contain.

Tracking Technologies

We, Point Inside, and our partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. Users can control the use of cookies at the individual browser level.

We partner with a third party to either display advertising on our website or to manage our advertising on other sites. Our third-party partner may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising, click here (or if located in the European Union click here). Please note you will continue to receive generic ads.

As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.

Security

Please refer to our Security Policy.

Retention

We may retain your information for as long as your account is active or for up to ten years, to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.

Changes to Our Privacy Policy

Because the web and Mobile Products are evolving mediums, we may need to change our Privacy Policy at some point in the future, in which case we’ll post the changes to this Privacy Policy on our Website and/or within the applicable Mobile Product and update the Effective Date of the policy to reflect the date of the changes. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

By continuing to use the Website or Mobile Product after we post any such changes, you accept the Privacy Policy as modified.

Contacting Us with Questions

For more information, or if you have questions about this Privacy Policy, please contact us at support@pointinside.com.

Privacy Policy: Text

Privacy Policy

Effective: April 5, 2020

 

Point Inside, Inc. ("Point Inside”, "we”, "us”, or "our”), the builder of the Point Inside platform, is committed to protecting your privacy. We know that you care about how information about you is used and shared, and we appreciate your trust that we will use that information carefully and sensibly in accordance with this Privacy Policy.

Please read this Privacy Policy carefully so that you understand our privacy practices. This Privacy Policy governs the personally identifiable information ("Personal Information” or “PII”) collected by Point Inside through our web SDKs, web APIs, and website at PointInside.com (the "Website”) and through mobile applications using the Point Inside mobile SDK (the "Mobile Product”). Except as specifically set forth below, the terms of this Privacy Policy apply to the Websites and our Mobile Products.

By visiting our Websites, you agree to the terms of this Privacy Policy with respect to your use of our Websites and any Personal Information that you may provide to us through the Website. If you are using one of our Mobile Products, whether provided directly by Point Inside or by one of our content partners ("Publishers”), your use of the Mobile Product will be governed by the terms of this Privacy Policy. This Privacy Policy will govern our collection, sharing, use, and security of your Personal Information and Non-directly identifying Personal Information. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information. If you do not agree to the terms of this Privacy Policy, you should not install the Mobile Product and/or should uninstall the Mobile Product immediately. Your use of the Mobile Product shall constitute your acceptance of the terms of this Privacy Policy.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Point Inside is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Point Inside may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

 

Trusted Partners

 

Trusted Partners are third party companies that have partnered with Point Inside.

  • Our Trusted Partners may include brands, data platforms, online advertising networks, and companies that perform research about consumer behavior, targeted or customized advertising, or human traffic patterns.

  • Our Trusted Partners may share Precise and Geographic Location Data with us such as browser cookie IDs, mobile device IDs, IP address, device type, operating system, hashed email address, or hashed mobile ID (e.g., Apple IDFA or Android advertising ID), as well as location-based data such as Wi-Fi, cell tower, GPS or diagnostic location information, contextual information, and demographic information including age, gender and zip code.

  • Point Inside may receive Precise and Geographic Location Data from third-party partners including Cuebiq and Reveal Mobile.

 

Privacy of Children

 

Protecting the privacy of children is especially important. For that reason, Point Inside does not knowingly collect any Personal Information from anyone under the age of 13. In no other way do we knowingly collect or maintain personally identifiable information from persons under 13 years of age, and no part of our Website is directed to persons under 13. If Point Inside learns that Personal Information of persons under 13 years of age has been collected through its Website or a Mobile Product, then Point Inside will take the appropriate steps to delete this information.

 

Information Collection and Use

 

Website

Point Inside collects data from our websites and applications as follows:

  • Information you provide: You are not required to register or actively provide any Personal Information in order to browse our Website and learn more about our company, our products and our technology. We may actively collect Personal Information from you when you voluntarily provide it to us, and it is needed to provide you a service. For example, we will collect your email address if you provide it and want to subscribe to our newsletter.

  • Browser-Level Information: When you browse our Website or use any of our Mobile Products, our web server automatically collects limited information about your computer configuration or device or, such as the type of browser software you use and the operating system you’re running and your IP address.

  • Non-directly identifying Personal Information: Point Inside does log these types of information which may include IP address, profile information, browser type, browser language, referring / exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, from users and visitors to the Website and the type of mobile device you use, the IP address of your mobile device, your mobile operating system, and the type of mobile browsers you use. This data is used to manage our Website, including diagnosing problems with our Website, track usage and improve the Website. User IP addresses are recorded for security and monitoring purposes.

  • Use of Cookies: Cookies are small files placed on your computer’s hard drive by a website when you visit. These files identify your computer and record your preferences and other data about your visit so that when you return to the site, the site knows who you are and can personalize your visit. For example, cookies enable a Web site shopping cart to function so that you only have to check out once. Consequently, cookies are often tied to the use of personally identifiable information while using our site, and some functionality may be lost if you choose not to accept the use of cookies. In general, we use cookies to collect information so that we can determine how to improve our site by seeing which areas and features are most popular; to personalize the site; and to complete transactions you have requested. We also use a session-based cookie that maintains a user’s session for continuity of navigation while viewing the site. After closing the browser, the session cookie simply terminates. Depending on the phone or device being used, cookies may be stored locally on the phone or device, or on servers operated by Point Inside. This Internet cookie-like functionality is in place for the same reasons and designed for the same purposes as cookies placed on your computer when interacting with Internet Web sites.

  • Use of Web Beacons: A Web beacon, also known as a Web bug, is a small, graphic image on a Web page, Web-based document or in an email message that is designed to allow the site owner or a third party to monitor the address and other information of the computer viewing the item. Web beacons are often invisible to the user because they are typically very small (only 1-by-1 pixel) and the same color as the background of the Web page, document, or email message. Web beacons are represented as HTML IMG tags in the Web page; users can click on view profiles of the Web page to see whether the page is using a Web beacon. Web beacons collect the IP address of the computer that the Web beacon is sent to, the URL of the page the Web beacon comes from, and the time it was viewed. Web beacons can also be linked to personal information. Point Inside does not place Web beacons that link to personal information on other sites, nor does it permit third parties, other than those working on our behalf, to place them on our site. Point Inside does use Web beacons itself and may link a particular beacon to personal information. For example, we may use a beacon to ensure a user can flip between technical assistance, customer service and our online store and still be recognized as our customer.

Mobile Products

Point Inside provides SDKs for each of the Android and iOS mobile operating systems (the "SDKs" or "Mobile Products") which collect data about mobile devices. These Mobile Products are often used via a Publisher’s own mobile properties, which act as a host for the Mobile Products. As such, use of the Mobile Products may come "indirectly" via use of a Publisher’s own mobile product. This Privacy Policy does not govern the use by a Publisher of any Personal Information you may provide to the Publisher through our Mobile Product, the Publisher’s mobile product, or otherwise. Before sharing Personal Information with any Publisher, you should review the privacy policy of the Publisher.

  • Personally Identifiable Information: We do not store Personal Information through our Mobile Products.

  • Automatically Collected Information: Other Non-directly identifying Personal Information When you use any of our Mobile Products, we automatically collect limited information about your computer configuration or device, such as the operating system the device is running and its IP address. Point Inside does log non-directly identifying Personal Information which may include IP address, profile information, browser type, browser language, platform type, domain names, the type of mobile device you use, the IP address of your mobile device, your mobile operating system, identifierForVendor and the type of mobile browsers you use. This data is used to manage the Mobile Product, including diagnosing problems with the Mobile Product, track usage, and improve the Mobile Product.

  • Mobile Advertising Identifiers: Both the Android and iOS mobile operating systems provide transient, resettable, and unique identifiers for the purposes of advertising; these are known as the Android Advertising ID and the Apple Identifier for Advertising (IDFA). Both identifiers have policies governing appropriate use, which the Mobile Products respect. The most important aspect of acceptable use of identifiers is respecting your ability to opt-out of its use. Point Inside collects these identifiers whenever the Mobile Products communicate with our server, if you have allowed your device to use these identifiers. These identifiers are considered to be non-directly identifying, can be reset and are randomly generated.

  • Location Data: By opting in to share your location data, the Mobile Product also allows us to collect information regarding your location, or the location of your device, by using GPS coordinates provided by your mobile device, or if you come within proximity of a Bluetooth Low Energy (BLE) device such as a beacon ("Location Data”). When any of our Mobile Products is open on your mobile device, we periodically receive Location Data. Most GPS-enabled mobile devices can identify a user’s location to within less than 50 feet. You can opt-out of our collection of such Location Data by turning off the GPS capability of your mobile device and rejecting our request to collect such data upon installation of the Mobile Product. If following installation of the Mobile Product, you wish to opt out of the collection of Location Data, you can change the preferences on your mobile device (by turning off the GPS capability for the Mobile Product) or by uninstalling the Mobile Product. If you choose not to permit the Mobile Product to collect such Location Data, certain of the Publisher’s services may not be available to you. Point Inside stores Location Data, and Location Data is passed through to the service providers and partners, including ad networks, ad serving companies and third-party information providers, as described below.

  • Aggregate Information Used to Serve and Target Ads: We may aggregate the information we collect from users of our Mobile Products and use this to target ads on digital out-of-home screens. Additionally, we may use information we collect from users of our Mobile Products to obtain consumer data (Third Party Data) from third parties (Third Party Data Providers); this is described in the next section. When we aggregate your information, no directly identifying personal information is included.

  • Aggregate Information Used for Location Analytics: We may aggregate the information we collect from users of our Mobile Products and Third-Party Data for reporting and analytics purposes. This is the same data we use to serve and target advertising and follows the same restrictions and guidelines. Location Analytics refers to the process of aggregating, packaging, and visualizing this data for particular physical locations.

  • Mobile Analytics: We use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.

  • Opt-Out of Information Collection: You can stop all collection of information by emailing optout@pointinside.com.

Point Inside collects information under the direction of the Publishers and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Publishers and would no longer like to be contacted by one of our Publishers that use our service, please contact the Publishers that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Publishers.

An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to the Point Inside Publisher (the data controller). If requested to remove data, we will respond within a reasonable timeframe.

We will retain personal data we process on behalf of the Publishers for up to ten years to provide services to the Publishers. Point Inside will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

 

Disclosure and Sharing of Information

 

Information about our customers is an important part of our business. We will share your personal information with third parties only in the ways that are described in this privacy policy. We share your personal information with other companies so that they can market their products or services to you. If you do not want us to share your personal information with these companies, contact us at privacy@pointinside.com

  • We may disclose your personal information to our service providers who work on behalf of Point Inside, including to provide our Website or the Mobile Product or fulfill user requests such as demographics databases. However, these companies are not allowed to share this information or to use it for their own purposes. These companies are authorized to use your personal information only as necessary to provide these services to us.

  • We may disclose your Mobile Advertising Identifiers to Third Party Data Providers for the purposes of acquiring additional consumer data. The Mobile Advertising Identifier acts as an index that can be used across datasets, similar to how cookies are utilized. These Third Parties have their own privacy policies that govern the use of the data they collect, which we do not control.

  • We may disclose your Location Data to third parties for the purposes of providing targeted advertisements and information our advertising partners believe may be of relevance and interest to you; these third parties include but are not limited to ad networks and ad serving companies. Advertising helps us provide the Mobile Product and helps our Publishers provide free services and content. You can opt-out of our collection of such Location Data by turning off the GPS capability of your mobile device and rejecting the request to collect such data upon installation of the Mobile Product or by emailing the Publisher to request opt-out on collecting such information.

  • In accordance with the practices as governed by the Publisher’s privacy policy, we may sell your Location Data to third parties, such as data marketplaces, at the request of the Publisher, in order to supplement the Publisher’s revenues.

  • We may disclose your Data to third parties to provide you with targeted information as requested by you. For example, we will provide your Location Data to a third-party partner so that they can provide you with location specific advertising.

  • We may disclose your Non-directly identifying Personal Information, which may include your IP address and as part of an aggregate data set to third parties for the purposes of providing targeted advertisements and information our advertising partners believe may be of relevance and interest to you.

  • We may disclose your personal information to lawful requests by public authorities, including to meet national security or law enforcement requirements, to comply with legal requirements or to respond to a subpoena, search warrant or other legal process or government request received by Point Inside, whether or not a response is required by applicable law.

  • We may disclose your personal information to enforce our rights in our Website and Mobile Products or to protect the rights, property or safety of members of the Point Inside community, our Publishers, other visitors to our Mobile Products, the public, or Point Inside and its employees.

  • From time to time you may be able to participate in contests, giveaways, or other similar promotions we sponsor. Except as explained otherwise in the rules for a particular contest, giveaway, or promotion, any personal information you provide will be used in accordance with this Policy.

  • As our business grows, we may buy or sell various assets. In the event that Point Inside or some or all of our assets are acquired by another company, our users’€™ personal information may be among the transferred assets. You will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. We may also disclose your personal information to any other third party with your prior consent.

  • In the event that Point Inside goes through a bankruptcy, reorganization, receivership or similar event, you understand and agree that we may not be able to control how your personal information collected by us is treated, transferred or used.

 

General Data Protection Regulation (GDPR)

 

As of May 25, 2018, the EU General Data Protection Regulation (GDPR) went into effect through the EEA countries and Switzerland. The GDPR requires that companies provide users with certain information about the processing of their “Personal Data” “Personal Data” is a term used in Europe that means, generally, data that identifies or can identify a particular unique user or natural “persona” for instance, names, addresses, cookie identifiers, mobile device identifiers, precise location data and biometric data.

To comply with GDPR, we provide the below representations and information, which are specific to persons located in EEA countries or Switzerland (so please do not rely on the below, if you’re not):

a. Legal grounds for processing your Personal Data

GDPR requires us to tell you about the legal basis we’re relying on to process any Personal Data about you. The legal basis for us processing your Personal Data for the purposes set out in the section entitled Information Collection and Use will typically be because:

  • You provided your consent. In order to provide our services that involve use of precise location information related to other Personal Data, (and to store and gain access to information stored on your device such as Device IDs), we rely on your consent. To obtain this consent, we rely on our own compliance steps and our web and mobile partners’ compliance steps, designed to ensure that consent is collected and passed on to partners, and to ensure that we only facilitate the collection of legally obtained data. We may choose to obtain consent in other cases as well, in which case we will adhere to applicable laws relating to such consent and its withdrawal. We also seek to obtain consent for certain partners with whom we work, who are often independent data controllers.

  • The processing is in our legitimate interest. In some cases, we use legitimate interest as a legal basis for processing Personal Data. We rely on legitimate interest when we use Personal Data to maintain the security of our services, such as to detect fraud or to ensure that bugs are detected and fixed. We also rely on legitimate interest when we use our own customers’ data (or Visitors’ data) to communicate with them about our Services or analyze our own Site activity.

  • Contractual Relationships. Sometimes, we process certain data as necessary under a contractual relationship we have (such as our customer records and contact information);

  • Legal Obligations. Finally, some processing of data may be necessary for us to comply with our legal or regulatory obligations.

b. Transfers of Personal Data

When we transfer Personal Data outside of the EEA or Switzerland, we take steps to make sure that appropriate safeguards are in place to protect your Personal Data. In general, our data transfers of our Personal Data are safeguarded by mechanisms such as Privacy Shield, European Standard Contractual Clauses, and Data Processing Agreements where this is required by European Data Protection Law. Feel free to contact us at the contact information below for more information about the safeguards we have put in place to protect your Personal Data and privacy rights in these circumstances.

As Point Inside works with global companies and technologies, we may need to transfer your Personal Data outside of the country from which it was originally provided. For instance, we may transfer your data to third parties that we work with who may be located in jurisdictions outside the EEA or Switzerland, and which have no data protection laws or laws that are less strict compared with those in Europe.

c. Personal Data Retention

As a general matter, we retain your Personal Data for up to ten years to provide our Services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements. Please note that we may retain this (and other) Information whenever and so long as we have a significant legal or operational need to do so, such as for auditing, corporate record-keeping, compliance accounting or security and bug-prevention purposes.

If you are a customer of ours and thus have an account with us, we will typically retain your Personal Data for up to ten years in order to serve the purpose for which it was collected, such as to provide you relevant information about our products and services.

d. Your Rights as a Data Subject

The GDPR provides you with certain rights in respect of Personal Data that data controllers hold about you, including certain rights to access Personal Data, to request correction of the Personal Data, to request to restrict or delete Personal Data, and to object to our processing of your Personal Data (including profiling for online ad targeting).

  • Right to Access: If you wish to exercise your right to access Personal Data we process as a data controller, you may do so by requesting access through the e-mail address privacy@pointinside.com. When we receive your request, we will provide you with current, step-by-step instructions to follow in order to obtain access. As we are required to verify a requestor’s identity prior to providing Personal Data, we will assess requests to exercise certain data access rights on a case-by-case basis: in doing so, we consider (a) the difficulty of verifying whether data that we hold and data we have linked to it truly and solely belongs to the data subject making the request, along with (b) the potential adverse effects on disclosure of personal data to the wrong individual. Because such improper disclosure would likely adversely affect the privacy rights and freedoms of the data subject, we may limit the Personal Data we make available. Please note that we will only grant requests for access for Personal Data for which we are a data controller, as explained further in sub-section (e) below. Where we act as a processor for one of our customers, we will refer your request to that customer. Please identify the customer your request refers to (if possible), to simplify this process.

  • Right to Correct: If you wish to exercise your right to correct Personal Data, you may do so by contacting us at the contact information below.

  • Right to Object to Processing or to Withdraw Consent: By using the device-based “opt-out” signals described in this Privacy Policy, you may withdraw consent for processing on which we rely on consent. If you do so, we will cease processing your Personal Data for purposes of our services within 30 days. We either collect these opt-out signals ourselves or receive them from the mobile apps we work with.

  • Right to Erasure. You also have the right to obtain the erasure of Personal Data concerning you that we hold as a controller. The above opt-out process satisfies this right. When a user opts-out through our partners (or through mobile device settings), and we receive this signal, we no longer use Personal Data to provide our advertising services. We will also manually delete your Personal Data if you prefer that we do so; please contact us and email your device to privacy@pointinside.com for further instructions if you wish to exercise this right manually. Please note, however, that we may retain copies of certain Personal Data on inactive or back-up files, for our certain important internal and purposes, such as auditing, accounting and billing, legal or bug-detection, for as long as is necessary to fulfill those purposes.

  • Right to Lodge Complaints. You have the right to lodge a complaint with a supervisory authority. However, we hope that you will first consult with us, so that we may work with you to resolve any complaint or concern you might have.

e. Point Inside as a data controller and a data processor

EU data protection law makes a distinction between organizations that process Personal Data for their own purposes (known as “data controllers”) and organizations that process Personal Data on behalf of other organizations (known as “data processors”). As noted above, we are not always a data controller of the data in our possession but are sometimes a data processor for other companies such as our customers. In such cases, we may direct your inquiry to the relevant data controller, since data controllers are the ones with primary responsibility for your Personal Data.

 

California Customers

 

Point Inside does not disclose customers’ personal information to third parties for the third parties direct marketing purposes, as governed by California Civil Code 1798.83.

 

Other Information

 

Access and Choice

Upon request Point Inside will provide you with information about whether we hold or process on behalf of a third party, any of your personal information. To request this information please contact us at privacy@pointinside.com.

If you wish to request access, or deletion of your personal information please contact us at privacy@pointinside.com. We will respond to your request within a reasonable timeframe.

Opt-Out

If you provide Personal Information to us through our Website, such as signing-up for our newsletter, you may request that we delete such Personal Information from our system, by sending a request to optout@pointinside.com, or by choosing the limit ad tracking setting on your device’s privacy settings page. We will promptly cease use of any such Personal Information and will remove such Personal Information from our servers in accordance with our standard practices. Certain other components of your Data relating to your use of the Website or Mobile Products, such as Mobile Advertising Identifiers, may be retained for up to ten years in order to serve the purpose for which it was collected.

Reset an Advertising Identifier

Resetting an advertising identifier is very easy on both iOS and Android (step-by-step guide below):

  • iOS: Go to Settings > Privacy > Reset Advertising Identifier and then Reset Identifier when the prompt comes up.

  • Android: Go to Settings > Google > Ads > Reset Advertising ID and click OK when the confirmation screen appears.

Social Media Sites, Links to Other Sites

We may have pages, accounts or presence on various social networking and media sites or services, such as Facebook and Twitter. Social media buttons or interactive mini programs that run on our website may collect your Internet protocol address, which page you are visiting on our website, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our website. Any information you post or provide through such social media sites and services will be subject to the policies of the applicable site or service.

The Website and Mobile Products may include advertisements and links to third-parties websites or service whose privacy policies we do not control. When you access another app or site, use of any information you provide on such site or app, and any information collected by the site operator, is governed by the privacy policy of the operator of the app or site you’re visiting. If you click through to any of the advertisers on a Mobile Product, the advertiser may also track your device. We do not have access to or control any information they may contain.

Tracking Technologies

We, Point Inside, and our partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. Users can control the use of cookies at the individual browser level.

We partner with a third party to either display advertising on our website or to manage our advertising on other sites. Our third-party partner may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising, click here (or if located in the European Union click here). Please note you will continue to receive generic ads.

As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.

Security

Please refer to our Security Policy.

Retention

We may retain your information for as long as your account is active or for up to ten years, to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.

Changes to Our Privacy Policy

Because the web and Mobile Products are evolving mediums, we may need to change our Privacy Policy at some point in the future, in which case we’ll post the changes to this Privacy Policy on our Website and/or within the applicable Mobile Product and update the Effective Date of the policy to reflect the date of the changes. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

By continuing to use the Website or Mobile Product after we post any such changes, you accept the Privacy Policy as modified.

Contacting Us with Questions

For more information, or if you have questions about this Privacy Policy, please contact us at support@pointinside.com.

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