LOCALSENSOR PLATFORM PRIVACY POLICY

Effective date: April 12th, 2018

KEY TAKEAWAYS

How did you get here?

You are probably using an app serving you news, weather data, traffic information or the like. The owner of the app maintains the app by means of serving you ads. This way the app can be offered for a lower fee or no fee at all.

How is Localsensor involved in this?

Localsensor helps advertisers to show great engaging ads to persons like you based on what we think you might find interesting. That is what we call interest-based advertising.

What do you mean by 'interest' in interest-based advertising?

We do our best to serve you ads that appeal to you. E.g. if you visit Amsterdam more than average we might serve you ads that show you local deals in Amsterdam. We are not interested in you personally (sorry :-/). We only try to reach large groups who might find something more interesting. This way you get more relevant ads.

You are not selling my data to other parties, right?

No, and we will never do that. We only use your data to serve you great ads through our platform.

When did you give your consent for this?

When you installed the app or at any other time the app asked you for your consent for advertising in this app.

If you want to reconsider all of this, where do you start?

You have the right to revoke your consent at any time. You can also reset your Advertiser Identifier in your device and your Advertiser Identifier link to segements will be wiped out completely. You also have the right to get the segments we have linked your the Advertiser Identifier with. Please drop us an email at privacy@localsensor.com

How can you manage your Advertiser ID?

Your Advertiser Identifier (ID) is directly managed by the operating system of your device being either android or iOS. For iOS you could visit the following link: https://support.apple.com/en-us/HT202074 and for Android you could go to: https://support.google.com/ads/answer/2662922?hl=en.

This Privacy Policy is meant to clearly inform you about the way Localsensor uses data related to you and about your rights with regard to this data. We therefore ask you to read this Privacy Policy carefully. Should you have any concerns or questions after reading it, please do not hesitate to contact us. Our team is always here to answer questions and to listen to any suggestions you may have for improving our services or policies. You can reach us at: privacy@localsensor.com.

A. ABOUT LOCALSENSOR

Localsensor B.V. is a private limited liability company incorporated under the laws of The Netherlands, having its registered offices in Amsterdam, The Netherlands, at the De Entree 234, Floor 4, Unit 4, 1101 EE. Localsensor is registered with the Chamber of Commerce under number 55634958.

You can always reach our Data Protection Officer at privacy@localsensor.com.

Localsensor is a mobile advertising technology company. We help companies to plan, execute, evaluate and optimize mobile in-app advertising campaigns via our platform (the 'Platform'). Our clients are companies of all sorts that wish to provide you with mobile in-app advertisements that are relevant and of interest to you. Our business partners are publishers that serve you these advertisements in their mobile apps.

B. LOCALSENSOR'S PLATFORM PRIVACY PRACTICES

WHAT PERSONAL DATA DOES LOCALSENSOR COLLECT AND PROCESS?

The personal data we use on our Platform includes data regarding your device (such as resettable Advertiser Identifier, device location and IP-address) and also data regarding operating system, network provider, device location, device model, the used app and interaction with the served advertisement.

We are keen to limit the collection of personal data to the bare minimum and make the data less specific to prevent personal identification with the data as much as possible.

FOR WHAT PURPOSES DO WE PROCESS PERSONAL DATA?

On our Platform, we use the personal data we receive from our business partners for limited and well-defined purposes:

(1) Programmatic Ad Buying and Ad Serving

a. First of all, after we receive the personal data, we directly use it to decide whether or not we will serve you an advertisement based on our clients advertising objectives.

b. If your personal data includes location data we might use this data to support the decision whether or not to advertise based on map data.

c. We also might adapt the advertisement shown based on your personal data.

(2) Interest-based Segments

On our Platform, we also use personal data to create segments. We process your personal data to improve the segments on our Platform. For this we use the pseudonymised Advertiser Identifier on your device. We use location data, IP-address, app and publicly available data, like statistical governmental data, to update our segments. This helps us to provide you with even more relevant advertisements in the future. We provide our clients with filtering options to manage the advertisements that are displayed to you and to target specific segments of users of the apps.

We will not create segments to such a degree that they can be linked to a single or small group of pseudonymised advertiser identifiers.

We will also never allow segments be used to harm your personal interests or interest of a group and we will also never allow segments to be used limit your fundamental rights and freedoms.

ON WHAT LEGAL BASIS DO WE PROCESS PERSONAL DATA?

For purpose (1) Programmatic Ad Buying and Ad Serving we only process your personal data if you gave your consent to our business partners in their app.

For purpose (2) Interest-based Segments we build segments in such a broad way that your personal interests and fundamental rights and freedoms are safeguarded. The legal basis for this is a legitimate interest of Localsensor to be able to help our clients to serve you ads in a much more efficient way so you get more relevant ads.

FROM WHOM DO WE RECEIVE YOUR PERSONAL DATA?

We receive your personal data from our business partners through their programmatic advertising selling platform.

HOW LONG WILL MY PERSONAL DATA BE STORED?

We will retain the data we receive from our business partners only for as long as is necessary for the purposes you gave your consent for. Once the personal data has served its purpose, it is immediately deleted.

For Ad Buying and Ad Serving (purpose 1) we will delete your personal data after 24 hours.

For Interest-based Segments (purpose 2) we will store your personal data for 24 hours and will only keep a pseudonymised (hashed) version of your Advertiser Identifier to link to interest segments. This interest segments we will delete after 12 months. Interest segments don't contain personal data.

HOW DO WE PROTECT PERSONAL DATA?

We take appropriate technical and organizational measures to protect personal data against loss or any form of unlawful use. For example, we limit access to this data only to authorized employees and contractors who need to know that personal data in order to perform their services.

We use hashing, encryption, pseudonymisation and de-identification techniques to ensure that the personal data in our segment database can in no way be linked to you as a person. This allows us to only identify your device for the purposes of providing our service and prevents your data being used to identify you in real life, either by us, our clients or our business partners.

WITH WHOM DO WE SHARE DATA?

We don't share your personal data we receive from our business partners with our advertising clients. We only share aggregate, non-individual data with our advertising clients. Insofar as this is necessary for ad delivery and associated services, we also share data from our database with our publishing partners.

We only share personal data with trusted technology service providers for processing based on GDPR compliant sub-processor contracts.

We will disclose personal data when obligated to do so by law, for instance to law enforcement authorities, our legal advisers or other third parties. We may also disclose personal data if this is necessary to enforce our terms and conditions or to protect our rights. This may also include exchanging data with other companies and organizations for fraud protection.

TRANSFER OF PERSONAL DATA TO COUNTRIES OUTSIDE THE EU

All personal data is stored within the European Union. We will not transfer personal data to outside the European Union.

HOW DO WE PROTECT CHILDREN?

We don't use our Platform to target apps from business partners that are mainly intended for children under the age of 13. We are not knowingly processing personal data of children. If we have accidentally done so and we discover this, we will immediately remove all related (personal) data from our Platform.

COOKIES

On the Platform, we do not collect data by use of cookies, beacons or the like.

C. YOUR RIGHTS

WHAT ARE MY RIGHTS REGARDING MY CONSENT, VIEWING, CHANGING, DOWNLOADING AND DELETING MY PERSONAL DATA?

Your consent is linked to your resettable Advertiser Identifier on your device. You can, at any time, reset or completely disable your Advertiser Identifier by following instructions through the following links, depending on your device:

iOS: https://support.apple.com/en-us/HT202074

Android: https://support.google.com/ads/answer/2662922?hl=en.

If you wish to know what segments your pseudonymised Advertiser Identifier is associated with on our Platform or if you wish to have this data changed, modified, downloaded or deleted, please contact us via privacy@localsensor.com.

HOW CAN I LODGE A COMPLAINT

Your rights regarding your personal data are of utmost importance to us. If you feel we haven't served you right we would really like hearing from you. You can also lodge a complaint with the Supervisory Authority. For The Netherlands this is the Autoriteit Persoonsgegevens (https://www.autoriteitpersoonsgegevens.nl)

D. MISCELLANEOUS

CAN THIS PRIVACY POLICY BE CHANGED?

We reserve the right to change, update or modify this Privacy Policy at any time at our sole discretion, and will post any new Privacy Policy here. Any such change, update or modification will be effective immediately. Please check our website regularly at www.localsensor.com/privacy.html.

QUESTIONS?

If you have any questions, please do not hesitate to contact us via privacy@localsensor.com.