EFFECTIVE DATE: APRIL 1, 2019
LOCALLY, (“Locally,” “we,” or “us”) is the owner of www.locally.io (the “Website”) and certain mobile applications and provides a variety of data products and services to assist clients with location technologies and location-based mobile strategies.
RESPONSIBILITY FOR YOUR INFORMATION
LOCALLY is the data controller with respect to all of the information, including Personal Information, collected from visitors to the Website and our mobile applications. The obligations of a controller are to provide you with information on what, why and how we process your information.
LOCALLY is not the controller of any third party websites or applications, even if such sites and/or applications are using our location technologies and services.
PERSONALLY IDENTIFIABLE INFORMATION
Our Website is not the main source of the information and data that we collect. We collect most of the information and data from our mobile applications and third parties that use our location technologies and services, such as data suppliers, partners, our clients and their data services partners. On our Website we automatically collect the type of web browser you use, your operating system, your Internet service provider, your IP address, the pages you view, and the time and duration of your visits to the Website. When you use a software application that uses our location technologies and services, among other, the following information and data may be collected:
- location data such as the geolocation of the device being used and time spent near points of interest;
- unique device identifiers and time and date information;
- certain event information and system configuration of the device that you are using; and
- information and data that does not identify individual users, such as operating system version and type, certain device settings, device time zone, device carrier, current IP address, applications installed on the device, and platform-specific advertising identifiers.
You cannot contact or communicate with us, through our Website, our mobile applications or otherwise, without telling us who you are and revealing Personal Information.
We will only process information about you when having a valid business reason to do so. In general, we rely on the following reasons to collect and process your data and information:
- deliver the information you request regarding products or services;
- with your consent keep you up to date on the latest product and service announcements and other information we think you’d like to hear about;
- upon your request or with your consent send you technical information, updates, security alerts, and support and administrative messages;
- monitor and analyze trends, usage, and activities in connection with the Website, our mobile applications and applications that use our location technologies and services;
- provide, maintain, and improve the Website, our mobile applications and our location technologies and services;
- provide products and services to assist clients and partners with location technology and location-based mobile strategies, such as targeted mobile sales and marketing strategies;
- To comply with legal obligations; and
- For legitimate interests after balancing your interests and rights.
If you choose not to provide the information we request, you will be unable to communicate with us through the Website and our mobile applications and receive certain information and services on our Website and mobile applications. We collect information about you in several ways. For example, we might ask for your contact information when you correspond with us, call us with a question, or request information on services. We also collect information, including Personal Information, when you participate in any interactive features of the Website or our mobile applications, fill out a form, or otherwise communicate with us via the Website or our mobile applications. In addition, when you register with us or ask to be included in an email mailing list, we collect and store the information and Personal Information you provide in a secure database.
USE OF INFORMATION AND DATA
We use information and data, including Personal Information, for purposes such as:
- administering our relationship with you, our clients and partners and third parties and responding to inquiries;
- business development including sending information on our products and services, updates, publications, and details of events;
- analysis of data and information, including, but not limited to location data, traffic patterns, consumer trends and patterns, and success of advertising and marketing campaigns;
- assisting our clients and partners with location technology and location-based mobile strategies, such as targeted mobile sales and marketing strategies; and
- meeting legal or other regulatory obligations imposed on LOCALLY, including, but not limited to, responding to subpoenas and warrants, defending the rights, property or safety of LOCALLY, our clients or other parties.
The above referenced description of uses is only a general description and is not an exhaustive list of all the ways we use information and data.
Personal Information may also be combined with other Personal Information and information and data (such as demographic information and past information requests) available from our records and other sources (such as public records). If you prefer not to be contacted by or receive promotional material from LOCALLY, please let us know by e-mailing us at firstname.lastname@example.org and put “unsubscribe” in the subject line together with the name of the publication you wish to unsubscribe from. Our marketing communications will also include an “unsubscribe” link.
SHARING PERSONAL INFORMATION
To provide and administer our Website and our mobile applications, we may need to share your Personal Information with our partners and different service providers or suppliers that we work with.
Additionally, we receive, administer, analyze and share data and information with our clients and partners and their service providers in the administration of our mobile applications and our location technologies, including but not limited to, device identifications, location data, traffic patterns and consumer trends and patterns. We may also disclose ‘blind’ aggregated data and user statistics to prospective partners and other third parties, and for other lawful purposes. Blind data is data which does not identify an individual person or disclose Personal Information. We may also disclose Personal Information with your consent or at your direction.
Please be advised that in certain circumstances, LOCALLY may be required to disclose your Personal Information to governmental organizations, attorneys and private agencies that conduct relevant criminal and civil investigations, or otherwise as required by our legal obligations.
RETENTION AND TRANSFER OF PERSONAL INFORMATION
We retain Personal Information as necessary to service our operation and use of the Website, our mobile applications and our services. We also keep Personal Information, meta data, documentation, and any other relevant information as permitted and/or required by law.
When the retention time is reached your information may be destroyed. You may also ask LOCALLY to transfer your Personal Information upon request. Please contact email@example.com to request transfer of your Personal Information or for more information regarding retention time and retention of information.
ACCURACY OF PERSONAL INFORMATION
We want to keep your Personal Information as correct and updated as possible. If your Personal Information is incorrect or has changed, please inform us by sending us an email to firstname.lastname@example.org.
YOUR RIGHTS AND COMMUNICATIONS
You have the right to make the following request to LOCALLY:
- Access your Personal Information (data subject access request);
- Correction of your Personal Information;
- Erase or transfer of your Personal Information;
- Restrict processing of your Personal Information;
- Object to the processing of your Personal Information; and
- Withdrawal of your consent for collection of Personal Information.
Following your initial contact with us, transaction or registration on our Website or mobile applications, we want to continue to communicate with you only if you want to hear from us. If you prefer not to receive information from us please let us know by sending your written request via email to email@example.com. Please provide your full name and email address, and describe specifically what information you do not want to receive. Please note that it may take up to two weeks for your request to become effective.
If you do not want LOCALLY to deploy cookies in your browser, you can set your browser to reject cookies or to notify you when a website tries to put a cookie in your browser software. Rejecting cookies may affect your ability to use of some of the services and functionalities at our Website and our mobile applications.
SOCIAL SHARING FEATURES
The Website and our mobile applications may offer social sharing features and other integrated tools (such as the Facebook “Like” button and the Twitter “Follow” button), which let you share actions you take on the Website and our mobile applications with other media. The use of such features enables the sharing of information with your friends or the public, depending on the privacy settings you establish with the entity that provides the social sharing feature. You use these social sharing features at your own risk. No security measures, including the privacy settings referenced above, are perfect or impenetrable. We cannot and do not guarantee that the information you share using such features will not be viewed by unauthorized persons. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.
LOCALLY uses commercially reasonable efforts to safeguard the security of information with physical, electronic, and managerial procedures. Likewise, we urge you to take every precaution to protect your Personal Information when you are on the Internet.
Because of the global nature of the Internet, when you give us information, that information may be sent electronically to servers outside of the country where you originally entered the information. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, we cannot ensure or warrant the security of any information you transmit to us or from our services, and you do so at your own risk.
THIRD PARTY WEBSITES
CHILDREN UNDER THE AGE OF 13
LOCALLY does not knowingly solicit Personal Information from children or send them requests for Personal Information. If you are under 13, do not use or provide any information on this Website or our mobile applications or on or through any of their features. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information.
CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 permits 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 contact us electronically at privacy@Locally.io or write to us at the address set forth below.
1 Technology Drive J-701
Irvine, CA 92618