Effective Date: November 6, 2017
In general, LotaData collects information about End Users’ devices (“Device Data”) from Customers that integrate LotaData’s products into their apps either through a software development kit (“SDK”) or from Customers that otherwise share Device Data with LotaData. Device Data collected by LotaData may include the following:
Device Data is generally used to operate, maintain and improve LotaData’s products and services for Customers. LotaData’s products and services help developers, publishers, advertisers, marketers and other companies and organizations in the public and private sectors to learn about End Users based on the Device Data. For example, LotaData may enable Customers to:
The above list is not exhaustive, but it is intended to provide illustrative examples of how LotaData uses the Device Data.
Before LotaData collects Device Data from an End User’s device, the End User must first opt-in to share the device’s location data. An End User is opted in when the End User downloads an app that includes LotaData’s SDK and gives LotaData permission to collect Device Data.
Apps on Apple devices, like iPhones, and Android/Google devices, like Samsung Galaxy, ask for permission to collect data in different ways. Older Android phones running older Android operating systems require an End User to accept any permissions that the app asks for before the End User can install the app. Thus, if the app has been downloaded, the End User is opted in. Newer Android phones allow End Users to opt-in after downloading the app. Apple apps also allow End Users to download the app without first opting in, however, Device Data is collected only after End Users opt-in.
End Users can choose to opt-out of sharing Device Data with LotaData by disabling location sharing or ad tracking on their devices. End Users can also disable location sharing with specific apps by reviewing the settings for each app, or by choosing to not share location when prompted after first downloading the app, or by uninstalling the app. If an End User opts-out of location sharing or ad tracking, LotaData does not collect Device Data from the End User’s device.
For iOS, ad tracking can be disabled by navigating to Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting. For Android, navigate to Google Settings app > Select Ads > Enable “Opt out of interest-based advertising.”
At this time LotaData does not honor web browser Do Not Track ("DNT") signals or similar mechanisms.
LotaData collects information that Customers provide when Customers set up an account, use LotaData’s products or services and/or the Website or communicate with LotaData.
For example, LotaData may request Customer’s contact and billing information (e.g., name, postal address, email address and password and telephone number) and applicable business information when Customers register for an account or purchase LotaData’s products or services.
Some of the features of the Website may be accessed by a Customer only after the Customer creates an account with LotaData.
When a Visitor is using the Website, LotaData may log information related to the Visitor’s usage of the Website, such as IP address, browser type, browser language, referring/exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages. LotaData also may log the Visitor’s type of mobile device and the mobile device’s IP address, operating system, and the type of mobile browsers. This data is used to manage the Website, including diagnosing problems, tracking usage and improving the Website.
LotaData provides Customers with access to a proprietary web application (the “Platform”) that provides the Customers with a visual mapping and tracking tool to analyze Device Data. In general, the Platform presents the Device Data in an aggregated and segmented form and does not provide a method for a Customer to identify, track or view End Users’ individual devices. For example, the Platform may enable a Customer involved in advertising to view an aggregated list of End Users’ devices that visited a particular movie theater on a particular weekend, or the Platform may provide a local government, as one of LotaData’s Customers, with recreation and parks analytics based on a group of End Users’ devices.
LotaData may provide a Customer with tools to track End Users’ devices based on device identifiers (e.g., IDFA or Advertiser IDs). However, these tools are provided only if the Customer already has the ability to track End Users’ devices (without LotaData’s tools) and has an app that’s using LotaData’s SDK.
Overall, the following list explains the ways in which LotaData may disclose Device Data and information collected from Visitors and Customers.
LotaData stores the Device Data and information collected from Visitors indefinitely for the purposes of operating, maintaining, improving and providing LotaData’s products and services, for the purposes of maintaining, operating and improving the Website and for other business purposes that LotaData considers reasonably necessary.
An End User may request to see and/or remove the Device Data associated with their device by emailing firstname.lastname@example.org. The End User will need to provide LotaData with the IDFA (iPhone) or Advertiser ID (Android phones). LotaData does not store email addresses, names, or phone numbers with End Users’ Device Data, so LotaData needs this identifier to find End Users’ device in the database.
A Visitor or Customer may request to see and/or remove information collected from the Visitor or Customer by emailing email@example.com. LotaData will first verify the identity of the Visitor or Customer, then provide and/or remove information collected from that Visitor or Customer.
LotaData uses reasonable physical, managerial, and technical safeguards to preserve the integrity and security of the Device Data and information collected from Visitors and Customers.
LotaData does not knowingly collect information from children under 13 years old or from websites or apps directed to children under 13 years old. LotaData’s products and services are not directed to persons under 13 years of age.
If LotaData learns that information of persons under 13 years of age has been collected or received, then LotaData will take the appropriate steps to delete this information.
This Section 9 (Dispute Resolution; Binding Arbitration and Class Action Waiver) only applies to End Users and Visitors (together, “Consumers”). For similar applicable provisions, Customers should refer to LotaData’s Terms of Service available at [ http://lotadata.com/terms_of_service ].
CONSUMERS SHOULD READ THIS SECTION 9 CAREFULLY. THIS SECTION 9 MAY SIGNIFICANTLY AFFECT CONSUMERS’ LEGAL RIGHTS, INCLUDING RIGHT TO FILE A LAWSUIT IN COURT.
LotaData complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. LotaData has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.