Last Updated: April 1st 2019
Locomizer Ltd, registered in England and Wales with company number 07667143 whose registered office is 207 Regent Street, 3rd Floor, London, England, W1B 3HH (Locomizer we, “us, and our), provides location data services to advertisers and location planners (together our Customers)
You can contact our Data Protection Officer (DPO) at the postal address above or by email at email@example.com.
- Background: Locomizer’s Services and Data Collection
Locomizer is a data analytics business that primarily focuses on the use of precise location data to help a variety of organizations develop insights about human behaviour based on their inferred and observed interactions with the physical world. The information we provide, for instance, helps marketers and advertisers learn about their potential audiences and customers, and helps Retailers plan where to site their stores.
- The Information We Use For our Services
Our data providers use or operate mobile SDKs (which stands for “software development kit”) or occasionally through other interfaces (APIs), in order to collect information, such as mobile identifiers (e.g., iOS IDFAs and Android Advertising IDs) and location information (as we describe below) which we require to perform our Services.
When you use an App that collects data indirectly on our behalf, we receive the following from our data partners:
- Location Data. This includes (a) Geolocation of the Device (if location services are enabled on the Device) and (b) dwell time near points of interest. We refer to this as Location Data. This is usually expressed by latitude-longitude coordinates obtained through GPS features of our SDK, WiFi data, cell tower triangulation or other techniques.
- Unique Device identifiers for advertising (Google Advertiser ID or IDFA). We refer to these as Device IDs. – The Device ID’s are hashed using the MD5 Algorithm, as Locomizer deals only with pseudonymised data in providing its Services. (see https://en.wikipedia.org/wiki/MD5 and Section 6 below)
(If you want to know more about how we collect, use and share information about our own customers and visitors to our Site, please go to Section 5.)
- How We Use the Information We Receive in Our Services
We generally use the information that we collect from Apps, SDKs and APIs for purposes of providing the Services, including as follows:
- Inferences from Aggregated Data. We mostly use the information we collect to make inferences about human location. Our algorithms use mobile location data as the starting point to record individual’s ‘affinities’ to nearby Points of Interest (POI), allowing us to profile the interest and affinities of audiences and populations in defined geographic segments.
- Interest-Based Segments and Ad Targeting. We use these ‘affinities’ to create “interest segments” that can be used to better target marketing in the physical world.
The above is not an exhaustive description of all of the ways the information we collect may be used: we may, for instance, sometimes customize uses of the information we have for certain customers. But the above describes the types of information that we collect, how we generally collect it, and what Locomizer focuses on. We provide more descriptions of our Services on our website so do visit it to find out more.
- How We Share the Information We Use and Collect In the Course of Our Services
We share the information we receive in order to perform our Services. Below is a more detailed list of how we could share the information that we receive:
We may disclose information about you:
- With Our Customers: We share aggregated information, such as interest segments, with our customers, which may include brands, data platforms, online advertising networks, Out of Home advertising companies and companies that perform research about consumer behaviour or human traffic patterns.
- External Service Providers (acting as processors) who provide services to us
- With our subsidiaries and related companies: We currently do not have subsidiaries or corporate affiliates, but if we do we may share any information that we hold with them.
- In connection with legal proceedings or process: When we are under a legal obligation to do so, for example to comply with a binding order of a court, or where disclosure is necessary to exercise, establish or defend the legal rights Locomizer, our customers or any other third party or to satisfy in good faith any applicable law, legal process.
- To Investigate Wrongdoing and Protect Ourselves or Third Parties. To enforce our rights and Terms of Service or other policies, or to investigate any potential violation of those Terms and policies, any potential violation of the law, or to protect ourselves, our customers, or any third party from any potential harm (whether tangible or intangible).
- In connection with a sale of our business: If a third party acquires some or all of our business or assets, we may disclose your information in connection with the sale (including during due diligence in preparation for the sale).
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Change of purpose.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- Information For Visitors to Site and our Customers
Locomizer, and service providers and vendors we work with, also collect information from visitors (Visitors) to our site at www.locomizer.com(the Site). This information refers to information voluntarily and directly provided by Visitors
- The information we collect from these Visitors to the Site and our Customers.
We collect information such as your name, address, phone number, and email address, if you provide it to us. For instance, you might provide us this information to register for an event, information about our services, or to set up an account on our system (in which case you might provide additional information to us, such as about your employer or in some cases, your payment information and may be given a username and password to access parts of our Site.
- How We Use the Above Information.
In addition to the purposes described above, we may use the information collected on our Sites to do the following:
- Provide Services to you.
- Respond to and communicate with you (including regarding news and updates about our Services).
- Send you offers and ads for our Services, when you browse the Site
- How We Share the Information We Collect Through the Site.
- We may share the Information with service providers who help us deliver the services you request or we provide.
- We may share the Information to communicate with you and market to you, including through email, direct mail or display media.
- We will disclose information about you if we believe in good faith that we are required to do so by law, regulation or other government authority or to protect the rights, safety or property of ourselves or any person or entity. We may also cooperate with law enforcement agencies and we may disclose any Information to the requesting agency in doing so.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets, a restructuring, or other corporate change or financing transaction .Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. We also may share the Information during the course of any due diligence process
We employ appropriate administrative, technical, and physical security measures to protect information contained within our systems from being lost used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
If you have any questions about the security of your information, please contact us through the contact information listed in Section 9.
- Data Protection Law
Data protection law requires Locomizer and those using our services to provide users with certain information about the processing of their Personal Data. Personal Data means, generally, data that identifies or can identify a particular unique user or device – for instance, names, addresses, cookie identifiers, mobile device identifiers, precise location data and biometric data. It does not apply to “anonymised data” as defined in data protection law but does apply to “pseudonymised data” which means that personal data cannot be attributed to a data subject without additional information. In providing its Services Locomizer only processes pseudonymised Location Data records and does not hold the information that would enable us to re-identify data subjects.
We also do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
- Legal grounds for processing your Personal Data
Data protection law requires us to tell you about the legal basis we’re relying on to process any Personal Data. The legal basis for us processing Personal Data for the purposes set out in Sections 2 and 3 above (and Section 5 as to visitors to our Site or our corporate customers) will typically be because:
- You provided your consent. In order to provide our services that involve use of precise location information related to other Personal Data we rely ultimately on your consent. To obtain this consent, we rely on our own compliance steps data collection partners’ compliance steps, designed to ensure that consent is collected and passed to us and to ensure that we only collect and process legally obtained data.
- The processing is in our legitimate interest. In some cases, we use legitimate interest as a legal basis for processing Personal Data. Including when we use: (i) Personal Data to maintain the security of our services, such as to detect fraud or to ensure that bugs are detected and fixed; and (ii)our Customers’ data (or Visitors’ data) to communicate with them about our Services or analyse our own Site activity.
- Contractual Relationships. Sometimes, we process personal data as necessary under a contractual relationship (such as Customer records and contact information);
- Legal Obligations. Finally, some processing of personal data may be necessary for us to comply with our legal or regulatory obligations.
- Transfers of Personal Data
As part of our activities we may transfer your personal data to other countries. We will always ensure we have a written data processing agreement with these processors to ensure the same level of data protection in the United Kingdom will apply.
- Data Retention
Locomizer retains Location Data for a limited period, sufficient to provide our Customers with the intelligence they need or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements. We store data as follows:
- Data segments. Data may be categorised into non-personal, non-sensitive behavioural segments, such as “movie goers” or “pet owners”. This abstract, categorised data is retained long enough to support Customer briefs and typically for less than 24 months.
- Location Data. We retain Location Data linked to Device IDs, typically for 24 months from receipt of such data from our partners.
- We will keep personal data we use for marketing for as long as we are able to market to you and if you withdraw your consent or opt-out of marketing communications, we will keep your contact details only to ensure that we do not contact you again for marketing purposes.
- If you are a Customer and thus have an account with us, we will typically retain your Personal Data for as long as required in order to serve the purpose for which it was collected, such as to perform our contract obligations and to provide you relevant information about our products and Services.
- Your Rights as a Data Subject
Data protection law R provides you with certain rights in respect of Personal Data that data controllers hold about you, including certain rights to access Personal Data, to request correction of the Personal Data, to request to restrict or delete Personal Data, and to object to our processing of your Personal Data (including profiling for online ad targeting).Right to Access: If you wish to exercise your right to access Personal Data (commonly known as a “data subject access request”) we process as a data controller, please contact our DPO at firstname.lastname@example.org. Where we act as a processor for one of our Customers, we will refer your request to that Customer. Please identify the Customer your request refers to (if possible), to simplify this process.
Right to Correct: If you wish to exercise your right to correct Personal Data, you may do so by contacting us at the contact information below.
Right to Object to Processing or to Withdraw Consent: You may withdraw consent for processing on which we rely on consent. If you do so, we will cease processing your Personal Data for purposes of our services within 30 days or less.You may also object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
Right to Erasure. You have the right (often referred to as the right to be forgotten) to ask us to erase Personal Data concerning you that we hold as a controller. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. When a data subject opts-out through our partners (or through mobile device settings), and we receive this signal, we no longer use Personal Data to provide our Services. We will also manually delete your Personal Data if prefer that we do so; please contact us and email details of your device to email@example.com for further instructions if you wish to exercise this right manually. Please note, however, that we may retain copies of certain Personal Data on inactive or back-up files, for our certain important internal and purposes, such as auditing, accounting and billing, legal or bug-detection, for as long as is necessary to fulfil those purposes.
Right to Lodge Complaints. You have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority. However, we hope that you will first consult with us, so that we may work with you to resolve any complaint or concern you might have so please contact us in the first instance.
- Locomizer as a data controller and a data processor
Data protection law makes a distinction between organisations that process Personal Data for their own purposes (known as data controllers) and organisations that process Personal Data on behalf of other organisations (known as data processors). As noted above, we are not always a data controller of the data in our possession, but are sometimes a data processor for other companies such as our customers. In such cases, we may direct your inquiry to the relevant data controller, since data controllers are the ones with primary responsibility for your Personal Data.
No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you. We may need to request specific information from you to help us confirm your identity and verify your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
- Contact Us
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
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