June 6, 2017
INFORMATION COLLECTION THROUGH OUR TECHNOLOGY
1. Information We Collect
Our technology solution (“Technology”) collects information regarding the physical and spatial position of a mobile device (“Position Information”). We use this Position Information mainly to assess and communicate to our Clients the likelihood that the person holding the device would be receptive to viewing an advertisement or other content. This helps our Clients and their customers provide more relevant ads and content at convenient times for you and avoid sending ads or content to you when you’re busy with other activities.
Our Technology does not collect your name, address, phone number, mobile phone number, e-mail address, credit card number or other similar information.
More specifically, our Technology enables our Clients to transmit to us anonymous data using technologies such as a mobile device’s accelerometer (whether a device is moving and how fast), gyroscope (orientation of a device), and magnetometer (direction a phone is facing or heading) to determine Position Information. Our Clients and their customers may employ software tags and similar technologies on the Client Properties in order to collect this information and transmit it to us so that we can assess it. As part of this process we may obtain from our Clients the device identifier of your mobile phone (“Device ID”) and information about your interaction with an ad, such as whether you clicked on the ad and what ad was delivered to you, and other non-identifying information, such as click stream information, web browser type, time and date.
We may also receive information from third party data providers who collect and make information available, such as behavioral, contextual and demographic information, for our Clients to use in targeting ads.
Our Clients are required to collect all such information in accordance with all applicable laws and to have the right to transmit such data to us.
2. How We Use Information and When We May Share and Disclose Information
We use information that we receive and collect through our Technology, including Position Information, to predict the likelihood that a user will be receptive to receive an advertisement at a given time. We share our prediction with our Clients, along with the Position Information, your Device ID and the time and date. Our Clients may use this information to determine whether to show you an ad or what ad to show you at a given time.
Our Clients and their customers may associate the prediction we make and the information we provide with other information that you have provided to them or that they have otherwise collected from or about you, which may include personally identifiable information, such as your name, email address, and mailing address, and other demographic and behavioral information about you. Our Clients may also associate the device identifier associated with your current device to device identifiers associated with other devices that you may use (e.g., your computer, tablet, or phone) in order to measure and target advertisements or content tailored to your interests across your devices. Our Clients’ and their customers’ use of the information we share with them will be governed by their privacy policies.
From time to time, we may establish a business relationship with other businesses whom we believe trustworthy and who have confirmed that their privacy practices are consistent with ours (“Service Providers”). For example, we may contract with Service Providers to provide certain services, such as data storage and hosting. We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider must agree to use reasonable security procedures and practices appropriate to the nature of the information involved, in order to protect your information from unauthorized access, use, or disclosure.
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose information that we collect to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate in order to respond to legal requests (including court orders and subpoenas), to protect the safety, property, or rights of our company or of any third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law.
3. Opting Out of Our Technology
If you prefer not to receive ads based on information collected through our Technology, you can opt out at any time by sending an email request to email@example.com. Opting out will disassociate your data from our Technology and will prevent ad targeting by our Clients or their customers using our Technology. Please note that if you opt out of our Technology, you may still receive ads from our Clients that are served without use of our Technology. Please also note that exercising this opt out may only be effective with respect to the specific device that you are using when you exercise the opt out. To effectively opt-out of our Technology with respect to all of your devices, you must opt out separately on each device.
Some of our Clients and their customers may also provide the ability for you to opt out of receiving targeted advertising by visiting http://www.networkadvertising.org/choices/ or http://www.aboutads.info/choices/.
INFORMATION COLLECTION THROUGH OUR WEBSITE
We collect certain personal information from our website at https://www.vlcty.net/ (“Website”) when you choose to provide it to us, for example, if you submit a question or comment through our “Contact Us” page. We use this information only to contact you to respond to your inquiry. Once collected, we will maintain your personal information for as long as reasonably required to fulfill your request, carry out the purpose for which the personal information was collected, or satisfy our legal and business obligations.
We or our third party service providers may also collect certain information about your usage of the Website, such the type of web browser you use, what pages you access, the date and time of visits and your IP address, which helps us analyze our web traffic and improve the Website.
We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information transmitted to us. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted through our Technology or collected through our Website, we cannot and do not guarantee the security of any information in our possession.
We do not knowingly collect Personal Information (as defined in the Children’s Online Privacy Protection Act) from children under the age of 13. If we become aware that we have inadvertently received Personal Information from a child under the age of 13, we will delete such information from our records.
PROCESSING IN THE UNITED STATES
Please be aware that your information may be transferred to and maintained on servers or databases located outside your state, province, or country. If you are located outside of the United States, please be advised that we process and store all information in the United States. The laws in the United States may not be as protective of your privacy as those in your location.