PRIVACY POLICY

Last updated on September 27, 2016

1020, Inc. ("Placecast") is a technology company that provides a platform for data management, data analytics and advertising services on mobile devices, as described on our website at www.placecast.net.

This privacy policy (“Privacy Policy”) describes how we collect and use information from our own website and in connection with the services we provide to partners, including advertisers, suppliers of advertising inventory or publishers, as well as end users of websites and applications.

Your privacy is very important to us and we are committed to protecting it. Not only do we abide by applicable laws and regulations and follow industry best practices for mobile advertising, we also never sell or share personal information. We believe that there are effective ways to increase the relevance of advertising messages by using non-personal information. We also believe that we can, with your express permission, make marketing messages more useful to you by combining your personal information with other information.

For purposes of the Privacy Policy, personal information is information that can be used by itself to identify a specific individual and would allow us to determine the actual identity of and/or directly contact a specific living person. It includes information such as name, physical address, phone number and email address.

Please note that this privacy policy does not apply to our partners. We provide a Platform that enables our partners to manage their digital data subject to their own privacy policies. For information on how they handle personal information you provide through other web sites or through the use of our services in conjunction with theirs, please consult their privacy policies.

If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information and permitting the transfer of information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. and the use and disclosure of information about you, including personal information, as described in this Privacy Policy. Placecast complies with the Principles of the EU-US Privacy Shield Framework (see below).

1. WHAT INFORMATION DO WE COLLECT AND WHAT DO WE DO WITH IT?

Non-Personal Information Collected Independently from the Use of Our Services

We may collect and use non-personal information about you, including de-identified location and other mobile and online usage information, from our partners in order to create de-identified profiles which we aggregate into audience segments. For example, we may collect and use de-identified device location information provided by our telecommunications operator partners. This information does not enable us to personally identify you but may include a unique anonymous identifier associated with your device. Non-personal information collected from our partners is subject to their respective privacy policies and terms of services, not this privacy policy.

Non-Personal Information Collected When Using Our Services

When Placecast has the opportunity to deliver an ad to your device through a third party service, site or application, we may receive information about your device and location from third party ad exchanges and/or publishers. This information does not enable us to personally identify you but may include an advertising identifier created by your mobile operating system to store information on our servers and later retrieve it to provide our Services (Apple iOS’ IDFA and the Android Advertising ID are examples of advertising identifiers - for more information about advertising identifiers, please check the settings of your mobile device), your device’s IP address, browser type, carrier, device model and operating system, the location of your device at the time the advertisement opportunity was received form a third party, the application or web page viewed on your mobile device and/or the date and time at which those were viewed, as well as your interactions with advertising content. We utilize this non-personal information as part of our Services to perform several tasks, such as improving the relevance of advertisements published on your device as we believe that more relevant advertising is more useful to you in addition to being more effective for advertisers, limiting the number of times a specific advertisement is presented to the same user, providing an advertisement to only certain types of users, providing reports to a partner or client, or improving the quality and design of the services we offer.

Any such information is received in accordance with the third party application or website’s privacy policies and subject to their terms and conditions.

We store advertising identifiers collected via our services for a maximum of 180 days and we store targeting data associated with those identifiers on a 90-day rolling basis.

Personal Information Collected When Using our Services

When we provide direct marketing services on behalf of our partners, these services require the collection of personal information with your affirmative consent. The types of personal information collected may include mobile numbers, email address, as well as device IP address and location information.

We may also collect personal information when you visit our website(s), for example when you fill out our “contact us” form; when you use a service we provide on behalf of our partners; to deliver products, services, information, and content that you request from Placecast or its partners or advertisers; if you participate in any surveys, contests, or sweepstakes sponsored by Placecast; if you post or access any content on message boards, chat rooms, blogs, or other interactive features that we may offer; if you make any inquiries to us through our website(s); website administration, technical support or troubleshooting; or if you provide it to us when contacting us about this Privacy Policy or any customer service related matter. In such cases, we will only use such personal information to respond to your inquiry. However, we may retain an archival record of all such correspondence. We do not sell or rent data collected from our website(s).

We use personal information to operate, maintain, and provide services you have expressly requested and provide information and content that may be of interest to you. We also may use your personal information, combined with certain non-personal information, such as census data or weather data, to analyze user preferences and trends in order to improve the quality and design of the services we offer, and to create new features, promotions, functionality, and services either through our website or through our services.

We retain personal information collected through our services for as long as needed to provide the services to you. We will retain and use the information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. After that time the data is erased or anonymized, aggregated and stored for analytical purposes. When we dispose of personal information, we use commercially reasonable procedures to erase or render it unreadable.

Personal Information Collected On Behalf Of Advertisers

Some of our services help advertisers reach potential customers who may be interested in receiving information about their products or services. In response to an advertisement or marketing message, you may choose to directly provide personal information such as your name, address, mobile number and/or email address to an advertiser. Since this information is provided directly to a third party, Placecast does not have access to it. We strongly recommend that you carefully review these Advertisers' privacy policies and Terms of Use/Acceptable Use Policies before submitting personal information to them.

2. WITH WHOM DO WE SHARE THE INFORMATION WE COLLECT?

We may share non-personal information with partners, clients and vendors as permitted by law. We require our partners to comply with our Privacy Policy, to limit their use of such information, and to protect the security and confidentiality of this information.

We may share your personal information, only if you have provided prior express consent to do so, with our partners or advertisers so that they may use your information to communicate offers directly to you.

We may also share your personal information and/or non-personal information with other third parties under the following circumstances:

  • when we believe in good faith that the law requires it and/or if compelled to do so by law enforcement or government agencies, or to meet national security requirements, or by other legal action;

  • when we deem it necessary or appropriate to provide such information to law enforcement authorities; to protect our rights, or to take precautions against liability;

  • to protect users of our services from fraudulent, abusive, or unlawful use of, or subscription to, such services; in the course of a sale, merger, transfer, exchange or other disposition (whether of assets, stock or otherwise) of all or a portion of our business, in which case information we have collected or otherwise acquired may be one of the assets transferred.

In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, Placecast is potentially liable.

3. YOUR CHOICES

We believe in giving you choices when it comes to your personal information.

Our direct marketing services provided on behalf of our partners are permission-based, meaning that we only send marketing-related or promotional messages to mobile devices registered by users who have opted-in to receive them. You can choose not to submit your personal information to Placecast; If you submitted your personal information to Placecast and do not wish to receive text messages or e-mails from Placecast about products, services, or features that may be of interest, you can unsubscribe at any time. We will include an opt-out link or reply address in each e-mail or text message that we send on behalf of our partners. After unsubscribing, you will be removed from our database. Please allow up to 5 business days to process your request.

In general, you may choose whether to receive targeted advertising from many ad networks, data exchanges, marketing analytics and other service providers via the following organizations:

Placecast generally does not collect personal information through the Placecast service unless you have expressly consented to providing it to our partners, or via our website where you provided it to us. In most cases, if and/or when we obtain personal information, it relates to our current or prospective clients and business partners. You have certain access rights to your personal information contained in our systems. If you have submitted personal information through the Placecast services or website and wish to access, correct, or delete this personal information, please contact us at privacy (at) placecast.net.

4. LINKS TO OTHER (THIRD PARTY) WEBSITES AND APPS

We may provide links to content or advertisements that may be created, offered, sponsored or affiliated with other entities. Your access to and use of such content and advertisements - even when you have clicked on a link on this website to get there - are not governed by this Privacy Policy. Instead, they are governed by the privacy policies of those linked websites or mobile applications. Placecast is not responsible for your access to and use of such websites or apps, which includes any use of personal information that may be collected while you visit such websites or apps or when you engage in any transactions with the entities that operate those sites or apps. We strongly recommend that you carefully review these entities' privacy policies and Terms of Use/Acceptable Use Policies before submitting personal information to them.

5. HOW DO WE SECURE YOUR PERSONAL INFORMATION?

We take commercially reasonable efforts to maintain security protections in accordance with industry practices to protect data we collect from loss, alteration, destruction, misuse and unauthorized access or disclosure.

To prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of the personal information we collect, we have implemented physical, electronic, and administrative procedures. We utilize hashing, encryption and de-identification techniques to help ensure your privacy is safeguarded.

We have policies to help maintain control and physical security of the facilities used to store data and only allow access to authorized personnel, restrict access to data to those employees, contractors and agents that have a need to know the information in order to provide and support our services. All our employees are bound by confidentiality obligations and may be subject to disciplinary or legal action if they fail to meet these responsibilities.

We process information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.

6. CHILDRENS' PERSONAL INFORMATION

Placecast does not knowingly collect or solicit personal information from or about children under 13, except as permitted by U.S. federal law (for example, if a child under 13 sends us an email without being asked). If we discover that we have received any personal information from a child under 13 in violation of this Privacy Policy, we will delete such information from our servers and records promptly.

If you believe Placecast has any information pertaining to anyone under 13, please contact us at privacy (at) Placecast.net.

7. DATA FROM THE EUROPEAN UNION

Placecast complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Placecast has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. A violation of our commitment to Privacy Shield may be investigated by the Federal Trade Commission and/or the United States Department of Commerce. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page once it is available, please visit https://www.privacyshield.gov.

In compliance with the EU-US Privacy Shield, Placecast commits to resolve complaints about your privacy and our collection or use of your personal information. Persons from the European Union who have inquiries or complaints regarding this privacy policy should first contact us via: email at: privacy (at) Placecast.net.

Placecast has committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

8. CHANGES TO PRIVACY POLICY

Placecast reserves the right to change this Privacy Policy at any time. If Placecast decides to change this privacy policy, we will post the changes on this page and revise the “Last Updated” date above. Any changes to our Privacy Policy will become effective upon our posting of the revised Privacy Policy on this page. Use of the Placecast services or Site following such changes constitutes your acceptance of the revised Privacy Policy that is in effect.

9. CONTACT US

Questions and comments regarding this Privacy Policy should be directed to privacy (at) placecast.net or mailed to Placecast, Attn: Legal Department - 184 Rose Street, San Francisco, CA, 94102

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