Table of Contents
- Company Overview
- Description of Services Provided
- Service Provider Summary
- Expressed Opt-in Consent
- Information Collected
- Information You Give Us
- Information We Gather From Use of Our Services
- Use of Information We Collect
- Disclosure and Sharing of Information
- Cookies, Web Beacons, BLE and Device Signals
- Right to Access, Review and Change your Personal Information
- Opt-Out of Information Collection Practices
- Confidentiality and Security
- Third-Party Service Provider Practices
- Protecting Children
- Protecting Children Under 18 Years of Age
- Additional Terms and Conditions
- Privacy Shield
- Contact Us
Cphere is the leading provider of real-world location intelligence and marketing services. Our technology verifies mobile consumer attendance at millions of locations, points-of-interest and local events, providing deep insight into consumer activities, interests and personas. We provide our customers with services that include location-based intelligence, fraud forensics, data as a service and analytics services derived from inferred interests and matching of location data against place and event data. Our customers rely on our Data as a Service to power mobile advertising and digital marketing campaigns and use our data services to more deeply understand their customers, acquire competitive intelligence, to conduct law enforcement activities and enhance national security and to provide and enhance the services they offer to their own customers.
DESCRIPTION OF SERVICES PROVIDED:
Cphere collects and process various types of information from mobile devices which we receive from our third party partners. These third party partners are owners of mobile applications (“App(s)”) or data aggregators who may receive data from: (i) software development kits (“SDKs”) in Apps (SDKs allow developers to embed certain third party functionality into their own software applications), (ii) the mobile advertising bidstream (bidstream data is provided by publishers (websites that make ads available) or mobile apps and includes basic facts about an ad unit, such as URL, device type, IP address, location data, etc.), and/or (iii) Bluetooth beacons (these are devices placed in stores that emit Bluetooth signals and collect ID information of smartphones in their vicinity to provide related advertisements to those smartphones).
The data we receive from our Partners includes location data in the form of latitude/longitude (“Location Data”), which is associated with a mobile advertising ID, such as Apple’s Identifier for Advertisers (IDFA) or a Google Advertising ID (Advertising ID/Ad ID). Each mobile advertising ID allows us to identify each unique mobile device and is used by advertisers and marketers to display ads to your device. Using proprietary algorithms, Cphere cleanses, processes and merges the Location Data that we receive from all sources to create a portfolio of Location Data records for each mobile advertising ID. We also may receive other information from our third party partners about your device, such as IP address and Device User Agent Data (as defined below).
Additionally, we create virtual boundaries, known as geo-fences, around locations of interest, such as shopping centers, restaurants, and events, like professional sports matches, concerts, and county fairs. We then combine the Location Data we receive with our geo-fences, and other information that we create and collect about physical locations, such as venue, hours of operation, and events, and use such combined data to make inferences about the types of activities or events users of such mobile devices enjoy or spend time doing. We use the location data and the resulting inferences to provide our Data Services to our customers.
SERVICE PROVIDER SUMMARY:
Our Policy is provided to you to explain and describe to you how we collect, use, share, and disclose information collected via our Services. The following bullets provide a brief summary of some of the central features of our privacy practices, but you are encouraged to read the entirety of our Policy to gain a complete understanding of our privacy practices.
- We collect information (including both non-personal Information and personal information (each as defined below) from you in two principal ways, including information that you give to us and information that we collect from your use of our Service.
- We may share your personal information with third-parties in certain circumstances, including as necessary to provide you with our Services or certain aspects thereof, or in our discretion to third-parties for our or their own purposes. You can learn more about our information sharing practices below, by reviewing the “Disclosure and Sharing of Information” section below.
- You may review and under certain circumstances, update your personal information by contacting us at firstname.lastname@example.org.
- While we cannot guarantee, nor should you expect, that your information will remain secure, we do use commercially reasonable efforts to secure your information.
- Our Services are not directed to people under 18, as further set forth in the section titled “Children Under 18 Years of Age” below.
EXPRESSED OPT-IN CONSENT:
Cphere collects information from you in two ways: information you give to us, and information that we gather from your use of our Service, each is more specifically described and detailed below. The information we collected is comprised of both “personal Information” and “non-personal Information.” “Personal information” means information that you provide to us that personally identifies you, such as your first and last name, email address, physical address, telephone number, billing information, or social security number. “Non-personal information” means information that does not specifically identify you.
INFORMATION YOU GIVE US:
We collect information that you give to us. To the extent that our Services require you to submit information about yourself, for example through our Contact Us form, in order to receive information about our Services, we will collect and hold all such information, whether personal Information or non-personal information. In addition, may also receive information from you through the use of the Services. Information included in any postings on our Services, or your participation in surveys and research studies, any correspondence to us, and any content therein that you enter into the Services may be collected, retained, processed, and used by us in accordance with this Policy.
If you represent a business and want to partner with us, advertise with us, or participate in our Services in any other way, you may be asked to provide information such as a business name, website URL, telephone number, physical address, email address, description of business, service areas, business category and/or keyword information, credit card information, and other contact information (all of the foregoing, “Business Information”). Business Information may also include a business’s opt-in to receive additional information regarding services that we or our partners may provide. Some of the Business Information you provide to us may be personal Information. If this information is collected by us or our partners via telephone, you acknowledge and agree that we or our partners may be recording your telephone call for our training or quality control purposes during such call, as well as for use in accordance with this Policy.
INFORMATION WE GATHER FROM USE OF OUR SERVICES:
Just like many other websites and applications, we collect information about what parts of our Services you use and how you use them. Information we may collect includes, without limitation:
- Location information such as your geolocation when you use our Services from a mobile device and/or mobile application. We also may ask you to manually provide precise location information or to enable your mobile device to send us precise location information.
- Device information such as your hardware model, operating system, operating system version, mobile device type, unique identifiers from your computer or mobile device, application download information, and/or IP address.
- Computer or browser information such as your system activity, the domain name of the web site from which you linked to our Services, the time and duration of your use of our Services and any queries, browser type, and browser language.
For more information regarding what cookies are and how you can manage them as part of your use of our Services, please see the section titled “Cookies and Web Beacons” below. We may also use unique identifiers, Flash cookies, web beacons, web server log information, or other technologies to collect information about you. In addition to the information that we collect from you for our own Services, we may collect information from you for third parties for purposes such as ad targeting, optimization and reporting, as well as our other legitimate business purposes.
USE OF INFORMATION WE COLLECT:
We collect information from you and our other users to administer our business activities and to measure and improve our Services. Information is also used to fulfill your requests, conduct research, and develop new services and/or offer additional products and services to our visitors. For example, Cphere may use your IP address to determine which language to use to provide you when browsing web pages available through the Services. In addition, information collected from end-users may be used in aggregate form to, among other things, determine the total number of end-users who are using our Services, prepare utilization reports for our Partners (as defined below), diagnose and fix compatibility problems or other problems with our Services, and perform statistical analyses to enable us to build higher quality, more useful online Services. You understand and agree that we may use your information to process information requests you submit, to make you aware of new or other Services that we offer, or to help conduct surveys to assess and improve our Services, business and related products and services. Additionally, you understand and agree that we may use the information collected from you to show advertising and promotions tailored to your interests. If you submit a request for information about Cphere through our Services, we may use your e-mail address to assist you with any issues you may have or to send you an e-mail that gives you the opportunity to elect to receive periodic e-mail alerts from Cphere regarding developments at the company.
We may also use your e-mail address to send you important notices. Since this information is important to your use of our Services, you may not opt out of receiving these communications. We use Business Information to create accounts for businesses, to communicate changes to the Services, to improve the Services, to provide anonymous reporting for our internal purposes and for reporting to third-parties, and to market Cphere products and services, and those services of our Partners to such businesses. We may combine your personal information that we have with other information that we obtain from business partners or other companies. We may also combine your personal information with non-personal information. If we do so, the combined information will be treated as personal information for as long as it remains combined. We collect the following information when you browse or submit an inquiry on our Website, contact us to request information about our products or services, or apply for a job.
|Information Category||Description of Information Collected|
|Identifiers||IP address, and the following information if you choose to provide it to us: name, email address, phone number; job and company information, and state.|
|Device Information||Your browser type and operating system, time zone setting and location, browser plug-in types and versions.|
|Internet or Network Activity||Web pages you view, links you click, the length of time you visit our Site, and the webpage that led you to our Site.|
|Communications Preferences||Your preferences in receiving marketing from us and your communication preferences.|
|Professional or Employment Information||If you apply for a job, current or past job history or performance evaluations.|
We collect the following information about you from our Partners and use it to provide our Data Services:
|Information Category||Description of Information Collected|
|Location Data||Precise geolocation data, including latitude-longitude coordinates obtained through GPS tools, cell tower triangulation, WiFi data, or other techniques. We do not collect your precise geolocation in real-time.|
|Identifiers||IP address; mobile advertiser ID (“MAID”)|
|Internet or Network Activity||Timestamp, list of mobile applications from which location signals were received.|
|Device User Agent Data||Device type; browser family; browser version; operating system; version of operating system; device model number|
Cphere uses information we collect through our Website for the following purposes:
- Providing and Improving Our Services. We use your information to provide, improve, and personalize our services to you.
- Marketing and Communications. We use your information to communicate with you about our services, respond to your inquiries, administer surveys and questionnaires, to provide customer service, and for marketing and promotional purposes. For example, we may use your information to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you. We also may use the information that we learn about you to assist us in advertising our services on third party websites.
- Research and Analytics. To better understand how you access and use our Website, and for other research and analytical purposes.
- Legal Compliance. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
DISCLOSURE AND SHARING OF INFORMATION:
In providing our Services to you, we may find it necessary or beneficial to share your information with our partners, including our advertising, services and content partners (collectively, “Partners”) or allow such Partners to gather information directly from you. Some of this information that you provide to us or our Partners may include your personal information. As a service provider we may share your personal information with third parties in certain circumstances in the following situations as follows:
- Affiliates: We may disclose your information to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your information will be subject to this Policy.
- Service Providers: We may disclose the information we collect to third party vendors, service providers, and contractors or agents, who perform functions on our behalf.
- Customers: When we provide our Data Services, we share with our Customers your information, including your device’s location information, mobile advertising identifier, venues and events you attended, interest segments, and device information. Our Customers may use this information for purposes such as advertising attribution analysis and services; marketing and personalized advertising; market research, including consumer research; business intelligence, such as consumer insights, foot traffic and analysis; fraud detection analytics and services; movement intelligence analytics; security services; and federal law enforcement and national security services.
- Data Management Platforms and Third Party Ad Networks. We disclose your information, including your mobile advertising identifier and interest segments, to third-party ad networks to provide you with targeted advertisements, as more specifically described in the Third-Party Network Advertisers paragraph in the “Privacy Choices” section of this Policy. When you visit our Website, third party advertising providers collect information about your visit to track your responses to ads we have placed on other websites, and to inform our understanding of how users navigate our Website.
- Analytics Providers. We may disclose information we collected through our Website to our analytics providers such as Google Analytics, to evaluate usage of our Site, and to help us improve our services, performance and user experiences.
- Aggregate and De-Identified Information. We may share information that has been aggregated and de-identified with third parties for marketing, advertising, research, or similar purposes.
- Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
- In Response to Legal Process. We also may disclose the information we collect if we believe that such action is necessary to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
- With Your Consent . We may disclose the information we collect from you with your consent.
Please contact us at email@example.com to initiate any deletion and prevent our further use or distribution of your Business Information.
We reserve the right to share your non-personal information publicly and with others. Transfers of your information shall at all times be in accordance with applicable law. Cphere disclaims any liability or obligation as a result of any third-party actions or omissions concerning your information, including those occurring as a result of our sharing and disclosure pursuant to this Section 5. We urge you to contact third parties directly with any issues you may have concerning their use of your information. Please see the section titled “Third Party Practices” below for more information on third-party use of your information.
COOKIES, WEB BEACONS, BLE AND DEVICE SIGNALS:
We may use the services of web analytics companies to help us measure the effectiveness of our Services. To do this, we allow the web analytics companies to include Web beacons and cookies on the web pages of our Services. The type of information collected via such Web beacons and cookies includes click-throughs by users and other similar information. By supplementing our records, this information helps us learn things like user preferences, click-through rates, how to improve our Services, and what kinds of offers our users like to see. Although our web analytics companies log this information on our behalf, we control how that data may be used. For more information about cookies please click here. To “opt-out” of receiving cookies from certain Ad Serving Partners, please click here.
RIGHT TO ACCESS, REVIEW AND CHANGE YOUR PERSONAL INFORMATION:
You can review and update your personal information by contacting us at firstname.lastname@example.org. In certain jurisdictions, this right includes the right to request information that we have collected about you be deleted. Upon your request, we will remove your personal information in accordance with applicable law, subject to the limitations set forth elsewhere herein.
OPT-OUT OF INFORMATION COLLECTION PRACTICES:
You can also opt-out of our information collection practices by clicking on the following opt-out link:
After you have selected the Opt-Out option above, we will stop collecting any information about you, transferring any information about to third parties, and will delete any information we have about you, except as set forth above with respect to Business Information.
CONFIDENTIALITY AND SECURITY:
THIRD PARTY SERVICE PROVIDER PRACTICES:
Our Service Provider Partners are obligated by applicable law to protect the privacy of certain types of data; however, we are not responsible for their actions or omissions, including the manner in which they use information that they receive from us. Nevertheless, if you feel that any of our Partners, or any third party who claims association with Cphere, is improperly collecting or using information about you, we urge you to contact them directly and also to inform us by e-mailing us at email@example.com.
We comply with the Children’s Online Privacy Protection Act (COPPA). For more information about COPPA and children’s privacy, please click here. When we use the term “parent” below, we mean to include legal guardians.
CHILDREN UNDER 18 YEARS OF AGE:
Our Service is not directed toward persons under the age of 18. If you are under the age of 18, you are prohibited from using or accessing our services and may not give us any personal information or participate in any part of the services provided. Except as may be required by law, we will not knowingly collect, maintain, or disclose any personal information from children under the age of 18. We do not intentionally gather personal information about visitors or end-users who are under the age of 18. If you believe that we have collected personal information about a visitor or end-user who is under the age of 18, please contact us at firstname.lastname@example.org and such account and/or personal information will be removed and deleted.
ADDITIONAL TERMS AND CONDITIONS:
Cphere complies with the EU-US Privacy Shield Framework, as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the EU to the United States. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall take precedence. To learn more about the Privacy Shield program, the Privacy Shield Principles, please visit www.privacyshield.gov.
California Civil Code Section 1798.83 permits end users who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an e-mail at email@example.com or mail us at Cphere, 2425 Olympic Boulevard, Santa Monica, CA 90404.