Last Updated: May 2020
Section 1. Summary Information
- To the extent that we collect information, including Non-Personal Information and Personal Information (both defined below) from you, this may be done in two ways: information that we collect in connection with your use of our Services and information that you give to us.
- Your Personal Information may be shared by us with third-parties in many ways, including to provide you with the Services, or for our or their own purposes. To learn more about our rights to share your information, please see the How Do We Share This Information? section below.
- In some circumstances we allow you to review and update your Personal Information by contacting us at firstname.lastname@example.org.
- While we use commercially reasonable efforts to secure your information, we cannot guarantee and you should not expect, that your information will remain secure at all times and in all circumstances.
- Our Services are not directed to children under 13. Please see the Age Limitation section below for further information regarding our policy in this regard.
Section 2. What Information Do We Collect?
The information we collect about you may include the following:
- Information you provide us. We collect the content, communications and other information you provide when you contact us, including your email address.
- Information we obtain from your use of our Services. We collect information about the Services that you use and how you use them. This information includes:
- Device Information
We collect device-specific information (such as your hardware model and operating system version).
- Log Information
When you use our Services or view content provided by the Company, we automatically collect and store certain information in server logs. This includes:
- Search activity when you use web search services (such as search queries) (“Search Data”).
- Internet protocol address (“IP Address”)
- The type of browser you are using when using our Services, including your browser’s “user agent” (e.g., Internet Explorer, Safari, and other browsers)
- Device event information such as crashes, system activity, hardware settings, browser language, and the date and time of your request and referral URL
- Your geographic location
- The Domain name of your Internet service provider
- The source of traffic acquisition
- Date of traffic acquisition, and
- Time and date of certain browser events such as:
- Chrome extensions enabled
- Homepage/new tab rendered
- Search query performed
- Search performed on search engine results page (“SERP”)
- Search term on SERP
- Paid advertisements clicked on SERP
- Organic advertisements clicked on SERP
- Icons clicked on Home page/New Tab Page
- Uninstalls of extension
- Views on landing page
- Clicks on an action button on landing page
- Cancellations of an extension installation
- Acceptance of extension installation
- Disablement of extension
Section 3. How Do We Use This Information?
We are able to deliver, personalize, and improve our Services by combining and using the information that we have about you to understand how you use and interact with our Services. We also may use the information that we have about you for the following purposes:
- To provide, maintain, improve, and develop relevant features, Content, and Services.
- To communicate with you by responding to your requests, comments, and questions, including through any contact information (email or mobile text number) you provide us.
- To help advertisers and publishers connect with you to offer relevant advertising in their apps and websites.
- To create analytics and reports for internal purposes. These analytics and reports may include aggregate or anonymous information.
- To detect and defend against fraudulent, abusive, or unlawful activity.
In connection with the foregoing, we may combine your Personal Information that we have with other information that we obtain from service providers or other companies. We may also combine your Personal Information with Non-Personal Information. When Personal Information and Non-Personal Information is combined, it will be treated as Personal Information for the duration of such combination.
Section 4. How Do We Share This Information?
We will not share the Personal Information we collect about you with any third party for their own marketing purposes without your consent. Except as set forth below, we do not share information that individually identifies our users with companies, organizations or individuals outside of the Company and its affiliated entities. We will share your information in the following ways:
- Our vendors, subcontractors and business partners (“service providers”):We may share your data with our services providers who process your Personal Information to provide their services to us or on our behalf, which services may constitute a part of our Services. We have contracts and/or arrangements with our service providers that prohibit and/or limit them from sharing the information about you that they collect or that we provide to them with anyone else or using it for other purposes.
- Companies within the Company’s group of companies:We may share your information with our parent company and our affiliates, which are entities under common ownership or control of our ultimate parent company.
- Fraud prevention:We may disclose the Personal Information we collect about our users, including you, when we believe disclosure is necessary to investigate, prevent, or respond to suspected illegal or fraudulent activity or to protect the safety, rights, or property of us, our users, or others.
- Law enforcement purposes and public safety:If requested or required by government authorities, such as law enforcement authorities, courts, or regulators, or otherwise to comply with the law, we may disclose any information we have about our users. We may disclose information collected about you in order to exercise or protect legal rights or defend against legal claims. We also may be required to disclose a user’s Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
- Sale or merger of our business:We may transfer your Personal Information to a third party if we or any of our affiliates are involved in a corporate restructuring (e.g., a sale, merger, or other transfer of assets).
We may currently or in the future use web analytics companies to assist us in measuring the effectiveness of our Services. This requires that we allow such web analytics companies to include their own Web beacons and cookies on the Services. These web analytics companies collect information from Web beacons and cookies such as click-throughs by users and other similar information. We use this information to help us learn things like overall user preferences, click-through rates, means to improve our Services, and what the types of offers that are of most interest to our users. We control how that data may be used, notwithstanding its collection by third party web analytics companies.
Section 6. How Long Do We Keep the Information?
We retain the information we collect about and from you for as long as necessary to fulfill a business purpose or comply with a legal request. We may also choose to anonymize certain information you provide to us so that it can no longer be attributed to you if we would like to retain it for longer periods of time.
Section 7. How Do We Protect Your Personal data?
Section 8. Third-Party Practices
Applicable law obligates our service providers to protect the privacy of certain types of data. We are not responsible for their actions or omissions in any way, including with respect to any information they receive directly or indirectly from us. If you believe that any party who claims association with us, including our service providers, is improperly collecting or using information about you, you should contact them directly. You may also notify us by emailing us at email@example.com, though we maintain no responsibility to reply to such correspondence or to take any action in connection with such correspondence.
In order to provide or enable certain portions of our Services, our service providers may request or require you to provide information, including Personal Information, to them or to download certain software. We have no responsibility for the privacy practices of our service providers or the contents of any software downloaded from them. Our Services may also link to third party websites and offerings over which we exercise no control. Under no circumstances shall we be responsible for the privacy practices or the content of such third-party websites and offering, including their information collection, storage, usage and sharing practices. Please contact such third parties in connection with any issues you may have with respect to those third-party websites and offerings.
Section 9. Age Limitations.
We comply with the Children’s Online Privacy Protection Act (COPPA). Our Services are not directed to children under the age of 13. We do not knowingly collect information, including Personal Information, from children or other individuals who are not legally able to use our Services. If we obtain actual knowledge that we have collected Personal Information from a child under the age of 13, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13.
Section 10. Jurisdiction and International Data Transfers
We do not represent or warrant that our Services are appropriate or available for use in any particular jurisdiction. Those who choose to access the Services do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. We may limit access to our Services, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion.
Section 11. European Economic Area Privacy Rights
Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their Personal Information. Subject to any exemptions provided by law, you may have the right to request access to your Personal Information that we retain, as well as to seek to update, delete or correct this Personal Information. If you wish to exercise any of these rights, please contact firstname.lastname@example.org. While we may be able to provide you access to your Personal Information in some cases, there is no guarantee we will be able to provide access in all circumstances. In circumstances where we are unable to verify your identity or are required to retain such information in accordance with applicable laws, we may not be able to modify or remove your Personal Information. We will remove your Personal Information in accordance with applicable law.
To the extent that our processing of your Personal Information is subject to the General Data Protection Regulation, the Company relies on your consent. If we have collected and process your Personal Information with your consent, then you can withdraw your consent at any time by contacting us at email@example.com.
Subject to applicable law, you also have the right to (i) restrict the Company’s use of your Personal Information and (ii) lodge a complaint with your local data protection authority. If you are a resident of the European Economic Area and believe we maintain your Personal Information within the scope of the General Data Protection Regulation, you may direct questions or complaints to us at firstname.lastname@example.org.
Section 12. California Data Privacy Rights
California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us a list of what Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. To make such a request, please contact us at email@example.com . For all requests, you must put the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state and zip code. In the body of your request, please provide enough information for us to determine if this applies to you. You need to attest to the fact that you are a California resident and provide a current California address for our response. Please note that we will not accept requests via the telephone, mail or by facsimile, and we are not responsible for notices that are not labeled or sent properly or that do not have complete information.
Additionally, California residents are afforded additional rights under the California Consumer Privacy Act of 2018 (CCPA), including the right:
- to access the data about you that we collect;
- to prevent our sale of any of the information we collect about you to third parties by opting-out;
- to require that we delete any personal data (as defined under the CCPA) that we have collected about you;
- to know the categories of third parties to which we have sold data about you; and
- to know our reasons for collecting data about you (as is described in our Terms).
You can submit a request to exercise your rights above by mailing, emailing or calling us using the following information:
Position Mobile Ltd. SEZC
The Strathvale House
90 North Church St.
George Town, Grand Cayman, KY1-9012
Toll Free Number: 800-391-6751
When you assert your right to request information, you must confirm that you are a resident of the State of California. We reserve the right to request that you provide further evidence as a resident of California before acting on your request.
To opt-out of the Company from selling any of the information it collects about you to third parties and to delete all such information, we offer an “Opt-Out” Option, which can be accessed by emailing us at firstname.lastname@example.org.
Section 13. More Information.
Section 15. Contact Us