Last Updated: November 20, 2019
Cuebiq Inc., a U.S. company with registered office at 15 West 27th Street, New York 10001 United States (“Cuebiq” “we,” “us,” and “our”), provides online and mobile advertising and data services (the “Services,” as further defined below) to mobile application publishers (“Publishers”), advertisers (“Advertisers”), and partners (“Partners”).
1. INFORMATION FOR VISITORS OF THE CUEBIQ WEBSITE AND APP
In general, you may visit the Cuebiq Site without telling us who you are or revealing any information about yourself. When you contact us or submit an inquiry via the Cuebiq Site, we may collect personal contact information from you, which may include your name, address, email address, and phone number. We may use that information for internal purposes, including, among other things, to respond to your inquiries.
In addition, we may automatically collect technical information (collectively, “Analytics”) from the device you are using to access the Cuebiq Site, such as a desktop computer, laptop, mobile phone, tablet, or other internet enabled device (each, a “Device”). Technical information about your Device includes, but is not limited to: device type, operating system, settings and system configurations, IP address, Device ID and other unique Device identifiers, and mobile network information, as well as, your activity using the Cuebiq Site, such as data about the pages you access, traffic to and from our websites, the dates and times associated with transactions, web and app log data, and other event information, including crashes and system activity. We may use Analytics for research and internal purposes, such as to improve the Cuebiq Site so that it is more useful and accessible to you and provide relevant advertising to you. Analytics may be correlated with your Personal Data (as defined by the EU General Data Protection Regulation: 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) but not shared with any third parties.
We collect Analytics using certain technologies, such as:
- Cookies are small data files that have unique identifiers and reside, among other places, on your Devices, and on the web pages of the Cuebiq Site. Among other things, cookies help us improve and personalize your use of the Cuebiq Site. We may permit certain third parties to place cookies through the Cuebiq Site to provide us with better insights into the use of the Cuebiq Site and user demographics and to provide relevant advertising to you. These third parties may collect information about your online activities over time and across different websites when you use the Cuebiq Site. For example, we utilize Google Analytics to analyze usage patterns for the Cuebiq Site. Google Analytics generates a cookie to capture information about your use of the Cuebiq Site that Google uses to compile reports on website activity for us and to provide other related services. Google may use a portion of your IP address to identify its cookie and for its commercial purposes. If you wish to opt out of interest-based advertising click here, or if located in the European Union click here. Please note you will continue to receive generic ads.
- Web Beacons. Web beacons or “pixels” are electronic images that may be used on the Cuebiq Site or in emails we send to you. We use web beacons to deliver cookies, count visits, understand usage and effectiveness of offers, and tell whether you open an email and act upon it.
You may block, delete, or disable cookies or web beacons to the extent permitted by your browsers, applications, and Devices as described in more detail below. However, if you do so, the performance of certain features of the Cuebiq Site may be limited or not to work at all.
We may share Information collected from visitors of the Cuebiq Site as described below.
You may opt not to receive promotional emails from us by contacting us as indicated below or by following the “unsubscribe” instructions in any promotional email you receive from us, or by contacting us at email@example.com. Please note, however, that we may still send you non-promotional, transactional or service-related emails about your relationship with us.
2. DESCRIPTION OF CUEBIQ’S SERVICES
Cuebiq offers a location intelligence platform that provides marketers location-based, AI-driven analytics and measurement to map and measure the consumer journey, helping marketers answer strategic questions and make the right decisions in order to influence consumers through the sales funnel. We collect and process device identified data from users who consent to location data sharing via our partners apps for purposes related to advertising, attribution, analytics and research.
Cuebiq receives this location information either from an “SDK” (software development kit) that it provides to mobile application partners (“apps”) or from a server-to-server transfer and integration with mobile app partners. This location information includes data points such as lat/long (latitudinal and longitudinal) data, i.e., GPS-level data, and/or WiFi data (if feasible) associated with a mobile advertising ID, such as an IDFA on iOS platforms or a Google Play Advertising ID on Android platforms.
Advertising: We use the information we collect to make inferences about what types of activities users tend to spend time doing. For instance, we may notice a particular Device frequently at locations associated with sports (e.g., an arena), music (e.g., a concert venue), eating out (e.g., restaurants) or health and fitness (e.g., a gym or health club). We use this information to categorize Device users into “interest segments” – which advertisers can use to tailor advertising to those users who appear on mobile ad platforms they work with. To see examples of those segments, please click here.
Attribution: We also use some of the information we collect (including location information, IP Address or mobile advertising IDs) to help advertisers analyze aggregate ad performance – such as by measuring whether or how Devices that saw a particular ad, whether it be in the physical world, in the digital world, or on TV, tended to engage with a particular product. In addition, we sometimes use any or all of the above information to help advertisers better understand their customers or their marketing, such as for market research, customer analytics, or analytics of traffic patterns.
We sometimes collect the above data through “pixels” (described above) (“Pixel Data”), and we use such data to perform aggregated “attribution” analysis. This analysis can help marketers and their service providers understand which users have been exposed to which ad campaigns. This data may be measured or matched against aggregate location data in order to provide a “match rate” for an attribution study as to devices that have been detected at a given location – to provide similar services and analysis for marketers as those described above. For instance, if numerous devices that were sent an ad or offer for “Cuebiq Coffee” on Tuesday then went to a Cuebiq Coffee on Wednesday or Thursday, an advertiser might conclude that the ad campaign was successful.
Analytics: We help marketers better understand the offline consumer journey with location analytics that provide use cases, such as: offline competitive intelligence, market-share, consumer preferences, path-to-purchase and footfall analysis. This helps them identify areas of growth and activate those insights to drive performance. This may include sharing more detailed device and location information to allow marketers to bridge their own analytics with Cuebiq’s to develop combined aggregate insights.
Cuebiq may receive non-app user data through public data sources or data partners who aggregate public, user consented psychographic and demographic data, television content and ad viewing data, or other forms of transactional data such as purchase information. This information is used only to provide enriched views into aggregated analytics, is not used for advertising purposes, and is not shared with other partners.
Research: We work with research partners to allow them to derive inferences about traffic patterns supports causes such as improving the quality of life in underserved communities, natural disaster response, and smart city development through our Data for Good initiative.
We refer to all of the above services as the “Services.”
3. THE DATA ELEMENTS WE COLLECT IN PROVIDING OUR SERVICES
With your consent, when you have accessed or used an App that uses the Services, we collect certain information, including your Personal Data as defined under the EU’s General Data Protection Regulation or Personal Information under the California Consumer Privacy Act, (which we refer to collectively as “Information”) about your Device and your activity and interaction with such App, which may include:
- IP address
- Geolocation and proximity of your device if location services are enabled on your device and consent has been provided to the App to access those services
- Unique device identifiers such as advertising IDs (Google Advertiser ID or IDFA) – collectively referred to as “Mobile Ad ID”, vendor IDs and/or a pixel identifier
- Event information about your device, such as crashes, system activity, and hardware settings
- System configuration information
- Time and date information
- Dwell time at or near points of interest the device’s location services
- Other device movement information such as acceleration or altitude
The above Information is sent to our server in encrypted form, via an HTTPS protocol either through an Application Protocol Interface (“API”) or through a publisher that has licensed our software development kit (our “SDK”) thus providing the information through that SDK.
4. ADDITIONAL INTERNAL AND CORPORATE USES OF THE INFORMATION
In addition to the above descriptions of our usage of Information for our Services, with your consent we may also use Information to:
- Provide the Cuebiq Site and the Services, and notices related thereto, for example when you contact us or submit an inquiry via the Cuebiq Site, we may collect personal information from you, which may include your name, address, email address, and phone number
- Provide customer support for the Cuebiq Site and the Services, for example when you use the “Let’s Talk” form of Cuebiq Site, your personal information will be processed by Cuebiq for the sole purpose of replying to your queries
- Detect and protect against errors, fraud, or other criminal activity
- Collect fees and other amounts owed in connection with the Cuebiq Site and the Services
- Analyze, customize, and improve the Cuebiq Site and the Services
- Deliver targeted marketing and promotional offers to you
- Contact you by email message, push notifications, voice call, or text message, subject to applicable law
We do not use Information for employment eligibility, credit eligibility, health card eligibility, or insurance eligibility, underwriting, or pricing purposes.
5. HOW WE SHARE INFORMATION WE COLLECT
- If the information is provided to help complete a transaction requested by you or if you request or authorize it.
- To allow third parties, such as market research and information companies, to create datasets, perform market research, or create business intelligence or information products which analyze and monitor aggregated location behavior.
- To allow third parties to market to you, including through mobile devices and applications.
- When we partner with third parties, such as third party ad platforms, to provide the Services to you, or to support, analyze or improve those Services.
- Work with partners who employ our Information to connect user identities across devices – such as to inferentially “match” a mobile device by common IP address to a web browser or match a cookie ID to a Mobile Ad ID
- We may provide device information (such as IP address and/or Mobile Ad ID) to third party ad platforms, connected to interest segments, to help advertisers identify common users across different devices or browsers – for instance, to identify a common set of users on both mobile devices or tablets, as well as the web.
- If the disclosure is done as part of a purchase, transfer, or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, your Information may be one of the transferred assets, or in the course of due diligence for such an event) or in the event of bankruptcy.
- If the Information is provided to our third-party vendors or service providers to perform functions on our behalf (e.g., analyzing data, providing marketing assistance, providing customer service, processing orders, etc.). These companies are authorized to use your personal information only as necessary to provide these services to us, pursuant to written instructions.
6. YOUR PRIVACY CHOICES AND OPT-OUT RIGHTS
You have the right to request that we halt the further use of your Personal Data processed by Cuebiq (opt-out), request a copy of the information associated with your verified mobile device held by Cuebiq, as well as request that your Personal Data associated with your verified mobile device to be anonymized or erased from our systems.
When you request a copy of your information associated with your verified mobile device held by Cuebiq, we will provide (i) your Personal Data, (ii) the source of the Personal Data; (iii) the purposes and methods of the processing; and (iv) the logic applied to the processing. On our Partners page you will find the identifies of data controllers and data processors with whom we may share your Personal Data.
If you believe that the processing that concerns your Personal Data was unlawful or unnecessary for the purposes for which it was collected or subsequently process you have the right to lodge a complaint as outlined in Section 13 below.
Below you will find instructions on how you may exercise the above-mentioned rights by contacting Cuebiq using one of the methods listed:
Cuebiq provides multiple paths for you to retract your initial consent (Opt-Out) to data collection in connection with the Cuebiq Site and the Services, and to engage in other privacy controls such as access, portability and erasure.
- You may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser.
- You may limit the location information being shared with Cuebiq by deactivating location services for your device entirely or with the Cuebiq’s app partner more directly.
- You may limit the disclosure of certain Information by your mobile device to us and Publishers by adjusting the settings on your mobile Device. For iOS mobile devices, go to “Settings” from your Device’s home screen; scroll down to “Privacy”; select “Advertising”; and turn on “Limit Ad Tracking.” For Android mobile devices, go to “Google Settings” on your device; select “Ads”; and check the box labeled “Opt Out of Interest-Based Ads.” We honor these “limit” or “opt out” instructions or “flags” by removing recognized devices from our cross-app advertising or ad delivery and reporting solutions, on a going forward basis.
- Publishers and Advertisers may also provide ways for you to opt out from or limit their collection of information from and about you. Please refer to their privacy policies to learn more. Please note that Cuebiq is not responsible for the privacy practices of Publishers, Advertisers, and other third parties. Many of our partners provide you the option to opt out of certain advertisers’ cookies and browser-enabled, interest-based advertising at the Network Advertising Initiative’s website and the Digital Advertising Alliance (DAA) website.
- Please note that these opt outs only apply to interest-based advertising by participating advertisers. You may still receive other types of online advertising from participating advertisers, and the websites you visit may still collect information for other purposes.
- In addition, the opt-out choices you select are stored in opt-out cookies only in the browser that you use to visit the opt-out websites, so you should separately set your preferences for other browsers or devices you may use. Deleting browser cookies can remove your opt-out preferences, so you should visit these opt-out websites periodically to review your preferences or update your preferences to apply to new participating advertisers.
- Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not currently recognize or respond to DNT signals
Access, Portability, and Erasure
- To validate the source of privacy control requests we ask that you first download the Cuebiq App from the iTunes App store or the Google Play store.
- To receive a copy of data collected and retained at Cuebiq in relationship to your device please select “Request My Data” from within the App. We will confirm if any data has been collected from that device ID and provide that to you in a portable form if we have.
- To have data collected from your device that is held in device identifiable form be deleted from our servers, please select “Erase My Data” from within the App. We will confirm if any data has been collected from that device ID and begin the erasure process if we have.
- Please understand that if you have not opted out of Cuebiq’s Services, as described above, that data collection will continue even after an Erasure request.
When we collect information from your device (including precise location information) from mobile app partners, we endeavor to work with partners that provide disclosures to their own users regarding the use of mobile data for interest-based advertising purposes and available privacy controls. While the controls described above may impact the data collection or use of your Information by other companies, Cuebiq will only be able to directly apply these controls to the data that it possesses and controls. You may need to work with the mobile app Publishers, Advertisers, or our Partners directly to enact similar privacy controls, if offered, with them on the data they possess and control.
7. DATA RETENTION
We generally retain data related to Mobile Ad IDs on the following schedule: (a) we render Mobile Ad IDs inactive for interest-based advertising purposes within 120 days, (b) we continue to use Mobile Ad IDs for analytics purposes and other purposes unrelated to interest-based advertising and reporting (for instance, in aggregated form for market research) for up to 24 months, provided that we may retain them if we have a legal or significant operational or legal need to do so, such as for auditing, corporate record-keeping, compliance, record-keeping, accounting or security and bug-prevention purposes. We may retain anonymized data for longer.
We have administrative, technical, and physical safeguards in place in our physical facilities and in our computer systems, databases, and communications networks that are designed to protect the information contained within our systems from loss, misuse, or alteration. No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your Information. If you have any questions about the security of your information, please contact us as described below.
9. THIRD-PARTY WEBSITES OR APPS
10. INTERNATIONAL TRANSFERS
As Cuebiq works with global companies and technologies, we may need to transfer your Personal Data outside of the country from which it was originally provided. For instance, we may transfer your data to third parties that we work with who may be located in jurisdictions outside the EEA or Switzerland, and which have no data protection laws or laws that are less strict compared with those in Europe.
When we transfer Personal Data outside of the EEA or Switzerland, we take steps to make sure that appropriate safeguards are in place to protect your Personal Data. In general, our data transfers of our Personal Data are safeguarded by EU-US Privacy Shield program, European Standard Contractual Clauses, and Data Processing Agreements where this is required by European Data Protection Law.
11. CODES OF CONDUCT
Cuebiq is a member of the Network Advertising Initiative (NAI), and we undergo annual audits that we adhere to their strict Code of Conduct. To learn more about the NAI or how to opt out of receiving targeted advertising from other third party services that belong to the NAI, please follow this link.
13. REGULATORY AUTHORITY & CONTACTING US
Cuebiq, as a US based company, is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). For users in the EEA and Switzerland, Cuebiq complies with the Privacy Shield Principles as well as EU General Data Protection Regulation. Cuebiq is not liable for the data handling practices of our third-party partners except for those acting as Agents on our behalf. Under certain conditions, you may leverage binding arbitration in liability cases related to the onward transfer of personal data to those third parties acting as Agents on Cuebiq’s behalf.
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://feedback-form.truste.com/watchdog/request.