This is the LocationChoices (collectively “us” or “we” or “LocationChoices”) Privacy Policy (“Privacy Policy”) on behalf of LocationChoices and any LocationChoices affiliates, including LocationChoices’s sponsoring entity, Gimbal, Inc. This Privacy Policy is written to explain what information we collect, how we use it, whom we share it with, and the choices that we give you to control, access, and update your information.
LocationChoices participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. LocationChoices is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. LocationChoices complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, LocationChoices is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, LocationChoices may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
For questions regarding the Privacy Policy or practices, please contact LocationChoices at privacy [at] locationchoices [dot] org. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://www.jamsadr.com/eu-us-privacy-shield.
Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
LocationChoices complies with the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from Switzerland. LocationChoices has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view LocationChoices’s certification, please visit https://safeharbor.export.gov/swisslist.aspx.
LOCATIONCHOICES MOBILE APP (OR “LOCATIONCHOICES APP”)
The LocationChoices app includes the iOS and Android version of the LocationChoices mobile application.
1. What Information We Collect
Information you choose to give us. The LocationChoices App only collects your information where you actively submit it to us via the app. The relevant information collected is limited to the mobile device ID when a user submits an ‘opt-in’ or ‘opt-out’ request via the LocationChoices app.
2. How We Use Your Information
We may use your submitted device ID to facilitate communicating your preference to ‘opt-in or opt-out’ of location based advertising services from participating digital advertising providers.
This use includes:
- When a user ‘opts-out’, their corresponding device ID is included in a ‘blacklist’ of ‘opt-out’ devices and this preference is shared with corresponding LocationChoices partners who have agreed to respect this preference.
- When a user ‘opts-in’, their corresponding device ID is included in a ‘whitelist’ of ‘opt-in’ devices and this preference is shared with corresponding LocationChoices partners who have agreed to respect this preference.
- And any other use that we describe at the point where we collect data or information with your consent;
With our affiliates. We may share information within the LocationChoices family of companies.
As required by law or as necessary to exercise our legal rights. We may share your information as required by law, such as to comply with a subpoena, bankruptcy proceeding, or similar legal process when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others. Also, we may also share your information in the interest of protecting or exercising LocationChoices’s or others’ legal rights, e.g., without limitation, in connection with requests from law enforcement officials, to investigate fraud, to respond to a government request and in connection with court proceedings. In certain situations, LocationChoices may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In the aggregate or after de-identification. We may also share with third parties, such as advertisers, aggregated or de-identified and anonymous information that cannot reasonably be used to identify you.
4. How Long We Keep Information
We retain information for only as long as it is necessary to:
- Provide products and services to you and others;
- Perform or fulfill our contractual obligations;
- Comply with our legal obligations;
- Resolve disputes; and
- Enforce our agreements.
5. Access
Upon request LocationChoices will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by logging in to your account or by contacting us at privacy [at] locationchoices [dot] org for assistance. We will respond to your request within a reasonable timeframe. In certain circumstances we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service.
Your Choices & Privacy Protections
Safeguarding Your Data. To protect your privacy, we limit the amount of data that is sent to our servers. We take reasonable safeguards to help protect your personal information that we store on your device and that we transmit to our servers. If you have any questions about the security of your personal information, you may contact us at privacy [at] locationchoices [dot] org.
Transferring Your Data Across Borders. We may transfer your personal information outside your country of residence to countries or jurisdictions where we have facilities or to engage third parties to provide services to us for the purposes outlined in this Privacy Policy. Information collected within the European Economic Area (“EEA”) may, for example, be transferred to countries outside of the EEA. Such countries may not have the same level of data protection as within your country. If we do make such a transfer, we will use commercially reasonable efforts to ensure your personal information is protected.
Information of Minors
We do not knowingly solicit or collect personal information from or about children under 13 years of age, and we do not knowingly market LocationChoices products or services to children.
California’s “Shine the Light” Law
We acknowledge that California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year. Without your consent, we do not distribute your personal information to outside parties for their direct marketing, or any other purpose, except as provided for in this Privacy Policy.
Changes to This Privacy Policy
LocationChoices may change this Privacy Policy from time to time. LocationChoices encourages you to periodically review this page for the latest information on LocationChoices privacy practices. You will be deemed to have acknowledged and accepted any such changes by your continued use of the LocationChoices Site and/or LocationChoices Technology after the effective date. As required by law, LocationChoices will provide you with notice prior to any changes becoming effective.
Contact Us.
Please feel free to contact LocationChoices with any comments, questions, or suggestions you may have regarding the privacy practices. You may contact LocationChoices by email at privacy [at] locationchoices [dot] org, or writing to LocationChoices at:
LocationChoices
Attn: General Counsel
360 E. Second Street, Suite 350
Los Angeles, California, USA, 90012
Effective. December 3, 2019