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California residents (“Consumers”) should refer to Appendix A: Supplemental Information for California Residents Under CCPA below for more information.
EU residents (“Data Subjects”) should refer to Appendix B: Supplemental Information for EU Residents under GDPR below for more information.
Please read the following carefully to understand our views and practices regarding your information and how we will treat it. We will post any modifications or changes to the Policy on our Site. We reserve the right to modify the Policy at any time, so we encourage you to review it frequently. If we make any material change to the Policy, we will post a notice on our Site at the time the change takes effect.
As used in this Policy, "personal data" means any information relating to an identified or identifiable natural person (‘data subject’), including, for example, your name, postal address, email address and telephone number.
We will only process your personal data in accordance with applicable data protection and privacy laws. For the purpose of the EU General Data Protection Regulation (GDPR), the controller is Mobiquity Inc. of 51 Sawyer Road, Suite 410, Waltham, MA 02453, USA, and the controller's representative in the EU is Mobiquity B.V. of Barbara Strozzilaan 300, 1083HN, Amsterdam, The Netherlands. For the purpose of the California Consumer Privacy Act (CCPA), the covered business is Mobiquity Inc. of 51 Sawyer Road, Suite 410, Waltham, MA 02453, USA.
We collect information about you in a range of forms, including personal data. As used in this Policy, "personal data" means any information relating to an identified or identifiable natural person (‘data subject’), including, for example, your name, postal address, email address and telephone number.
We may collect information about you in the following ways:Information You Give Us. This may include:
Information From Social Networking Sites. Our Site includes interfaces that allow you to connect with social networking sites (each an “SNS”). If you connect to an SNS through our Site, you authorize us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Policy. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS.
Information We Get From Others. We may also get information about you from other sources. We may add this to information we get from our Site.
Information Automatically Collected. We automatically log information about you and your computer or mobile device when you access our Site. For example, when visiting our Site, we log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Site. We collect this information about you using cookies. Please refer to the section on Cookies.
We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Site; and (2) third party cookies, which are served by service providers on our Site, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.
Our Site may use the following types of cookies for the purposes set out below:
Type of Cookie
These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. [For example, they allow you to log in to secure areas of our Site and help the content of the pages you request load quickly]. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
These cookies allow our Site to remember choices you make when you use our Site, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our Site which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site.
Analytics and Performance Cookies
These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered does not identify any individual visitor. The unidentifiable information is aggregated and therefore anonymous. It includes the number of visitors to our Site, the websites that referred them to our Site, the pages that they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site.
We may use Google Analytics or other third-party analytics services for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies
You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
Targeted and advertising cookies
These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show adverts which we think will be relevant to your interests while you are on third party websites.You can disable cookies which remember your browsing habits and target advertising at you by visiting http://www.youronlinechoices.com/uk/your-ad-choices. If you choose to remove targeting or advertising cookies, you will still see advertisements but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored advertisements from companies that are not listed.
Social Media Cookies
|These cookies are used when you share information using a social media sharing button or “like” button on our Site or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.|
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com/uk.
If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Site.
We may use your information, including personal data or personal information, as follows:
We may share your information, which may include personal data or personal information as follows:
When we use the term “anonymous data”, we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party.
We may create anonymous data from the personal data or personal information we receive about you and other individuals whose personal data or personal information we collect. Anonymous data might include analytics information and information collected by us using cookies. We make personal data and personal information into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyze usage patterns in order to make improvements to our Site.
Our Site may contain links to third party websites, apps and features, such as Facebook “Like” buttons. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their websites, features or policies. Please read their privacy policies before you submit any data to them.
Our Site may offer various subscription services to registered users. Such services are fulfilled using provided information such as your name, email address or mobile phone number. Users have the ability to opt-out of receiving subscriptions at any time.
You may share personal data or personal information with us when you submit user generated content to our Site, including via forums, message boards and blogs on our Site. Please note that any information you post or disclose on our Site will become public information, and will be available to other users of our Site and to the general public. We urge you to be very careful when deciding to disclose your personal data, personal information, or any other information, on our Site. Such personal data, personal information, and other information will not be private or confidential once it is published on our Site.
If you provide feedback to us, we may use and disclose such feedback on our Site. We will collect any information contained in such feedback and will treat the personal data or personal information in it in accordance with this Policy.
As described in the Privacy Shield Principles, Mobiquity is accountable for personal data that it receives and subsequently transfers to third parties. Mobiquity, Inc. recognizes potential liability in cases of onward transfer to third parties. If third parties that process personal data on our behalf do so in a manner that does not comply with the Privacy Shield Principles, we are accountable, unless we prove that we are not responsible for the event giving rise to the damage.
We encourage you to contact us should you have Privacy Shield-related (or general privacy-related) questions or complaints. Our contact information is below in the “Contact Information” section. For any complaints that cannot be resolved with us directly, Mobiquity has chosen to use JAMS as a free independent recourse mechanism available to investigate individual complaints. You can find more about JAMS’ Privacy Shield independent recourse services here: https://www.jamsadr.com/eu-us-privacy-shield. As further explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means. Mobiquity is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
We seek to use reasonable organizational, technical and administrative measures to protect personal data and personal information within our organization. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us using the details in the Contact Information section below.
Users may be granted specific privacy rights based on residency and the applicability of local, state, national and international privacy laws. The list applicable privacy laws may include, but are not limited to:
EU General Data Protection Regulation (GDPR)
EU residents or “Data Subjects”
California Consumer Privacy Act of 2018 (CCPA)
|California residents or “Consumers”|
Personal Information Protection and Electronic Documents Act (PIPEDA)
Rights granted to users under applicable regulations may include, but are not limited to:
You may access the information we hold about you. If you wish to exercise this right, please contact us using the details in the Contact Information section below.
You may request that we delete the personal data or personal information collected about you.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion. We will retain your personal data or personal information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.
Our Site is not directed to children under 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us using the details in the Contact Information section below. We will delete such information from our files as soon as reasonably practicable.
Subject to the following paragraph, we ask that you not send us, and you not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Site or otherwise to us except in conjunction with applications we provide and manage for third parties that explicitly request such information.
If you send or disclose any sensitive personal data to us when you submit user generated content to our Site in connection with the use of those applications, you consent to our processing and use of such sensitive personal data as necessary to administer such applications in accordance with this Policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such user generated content to our Site.
APPENDIX A: SUPPLEMENTAL INFORMATION FOR CALIFORNIA RESIDENTS.
The Right to Access
You have the right to request access to the information we hold about you. You may also request disclosure of categories of information collected and/or sold to third parties within the past 12 months (where applicable). If you wish to exercise this right, please contact us using the details in the Contact Information section.
The Right to Know
You have the right under the CCPA to request that we disclose what personal information we collect, use, disclose, and sell.
The Right to Deletion
You have the right under the CCPA to request that we delete any personal information about you that we have we collected from you.
The Right to Opt-Out of the Sale of Your Information
You have the right under the CCPA to request that we do not sell any personal information that we have we collected about you.
Note: We do not currently sell any personal information.
The Right to Non-Discrimination
Consumers may exercise rights under CCPA without discrimination. For example, Consumers can exercise their rights their rights under CCPA without:
However, we may offer Consumers certain financial incentives which may result in a different price/rate or provide a different level or quality of goods or services. Although no financial incentives are offered presently, any CCPA-permitted financial incentives offered in the future will be reasonably related to the value your personal information provides us. A financial incentive requires your prior opt in consent, which you may revoke at any time.
Supplemental Categorization of Data for California residents:
Under CCPA, “Personal Information” is defined as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information includes, but is not limited to, the following if it identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household: categories of personal information collected include the following:
(A) Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
(B) Any categories of personal information described in subdivision (e) of Section 1798.80.
(C) Characteristics of protected classifications under California or federal law.
(D) Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
(E) Biometric information.
(F) Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
(G) Geolocation data.
(H) Audio, electronic, visual, thermal, olfactory, or similar information.
(I) Professional or employment-related information.
(J) Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).
(K) Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Right to Access
You have the right to access the information we hold about you. If you wish to exercise this right, please contact us using the details in the Contact Information section.
EU Data Subjects have the right to contact us to update or correct any inaccuracies in the personal data we hold about you. In your request, please make clear what personal data you would like to have changed, whether you would like to have your personal data that you have provided to us suppressed from our database or otherwise let us know what limitations you would like to put on our use of your personal data that you have provided to us. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Right to Submit a Formal Complaint
EU Data Subjects have the right to lodge a complaint with a supervisory authority. The supervisory authority or data protection authority in The Netherlands is called "autoriteit persoonsgegevens" and can be contacted via its website https://autoriteitpersoonsgegevens.nl/en.