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Privacy Policy

Position Mobile Ltd SEZC Privacy Policy

Latest Version as of February 2020

Prior to using our Products, including downloading, accessing, or installing our Products, we encourage you to read this Privacy Policy and our Terms of Services (the “Terms”) carefully.  By using our Products, you are agreeing to this Privacy Policy and the Terms in their entirety.  Undefined terms used herein shall have the meanings ascribed to them in the Terms.  References herein to the “Company”, “Position Mobile”, “we”, “us”, or “our” refers to Position Mobile Ltd SEZC.

Section 1.  About this Privacy Policy.

We have developed this Privacy Policy to describe to you our practices with respect to the information collected by us, including information about you, collected by or through the Products we make available to you, as well as information about you obtained from third parties.  This Privacy Policy is incorporated into our Terms of Service and is a binding agreement between you and Position Mobile.  If you do not agree with this Privacy Policy or the Terms, you are prohibited from using our Products.

This Privacy Policy describes how we collect, retain, process and share information in connection with your use of our Products, including without limitation, our search and discovery Apps, and outlines the manner by which you may access, modify, delete and gain further insight into our sharing of information about you in certain circumstances.  Please use the information described in this Privacy Policy to make an educated and informed decision about your privacy preferences in connection with your use of our Products and the exercise of your rights under this Privacy Policy.

Section 2.  Summary of our Privacy Practices.

In connection with the provision of our Products, we may make use of both Personal Information and Non-Personal Information (each as defined below) provided by you or collected from you or your computer and/or mobile device in connection with your use of our Products (collectively “Your Information”).  For information about our Products, please see our Terms. 

Information Collection

When you use our Products, we collect Your Information in a variety of ways, including information you directly provide to us in connection with your use of our Products, information derived from your computer systems and/or mobile devices as a result of your use of our Products or by virtue of having downloaded our Products, and information obtained from third parties.  Your Information may be Personal Information, Non-Personal Information or some combination of both.  For example, if you register to use our Products, then in connection with such registration, you may provide us with your name and email address and we will collect and retain this information.  In connection with your use of our Products, certain information may also be generated, such as the device ID or IP address from which you access our Products, as well as information regarding your use of our Products, such as search terms you enter in connection with your use of our search functionality and/or the types of Product Content with which you interact.

As used herein, “Personal Information” means information that you provide to us that personally identifies you.  Personal Information includes, but is not limited to, your first and last name, email address, physical address, telephone number and billing information, but specifically excluding Device Information and Log Information, as each of those terms are defined in Section 3 below. 

As used herein, “Non-Personal Information” means information that does not specifically identify you, including without limitation, Device Information and Log Information, such as data related to the searches you perform utilizing our search functionality.

Information Retention

We retain Your Information for so long as necessary to provide our Products to you and to otherwise utilize Your Information for the purposes outlined in this Privacy Policy.

Information Processing

We collect Your Information for a number of reasons, including (i) to provide you with the Products and the functionality of certain aspects of our Products, (ii) to share Your Information with third parties to the extent needed to provide you with the Products, functionality available through the Products, Third Party Offerings, and advertisements and other Product Content that is specific to you based on Your Information and preferences and/or may otherwise be of interest to you, (iii) to improve our Products, our business and/or Third Party Offerings, as well as the offerings and advertising of our clients and advertisers, (iv) to comply with applicable laws and other legal process, (v) to produce reports and other analytical insights for our business; and (vi) to ensure proper use of our Products, including in accordance with our Terms.

Information Sharing

We may share Your Information with third parties, including our partners, affiliates, advertising clients, and providers of certain Product functionality, including Third Party Offerings, such as our search functionality.

Information Accessibility

Depending on where you live and/or from where you access of Products, you may have the right to inspect, modify, delete, and/or restrict the types of Your Information that we collect about, including Personal Information and Non-Personal Information, as well as to learn with whom we have shared Your Information.

Section 3. Information That We Collect

We collect information, including Your Information, in a number of ways and this information may either be Personal Information or Non-Personal Information. 

Information Collected Automatically

By using and installing our Products, there is a lot of information generated and we collect this information.  Much of this information is Non-Personal Information, such as Device Information and Log Information (as defined below), as well as information derived from cookies and similar technologies. 

“Device Information” includes information related to the computer, mobile device or other system you utilize to access and use our Products, including the hardware model and the software systems on such device. 

“Log Information” is information obtained in connection with the use of our Product, which we collect on our server logs, such as

Information You Provide to Us

When using our Products, we also collect the information you provide to us.  Such information may include your Personal Information you provide to us when registering to use our Products, such as your name, telephone number, address, email address, username and password, among other information you may provide.  Such information may also include information, including Personal Information, accessible from third parties in connection with your use and/or installation of our Products, such as when you use social media login credentials (such as Facebook) to register for our Products.  We also collect and retain Your Information in relation to Your Content that you make available through our Products, such as photographs and other content.

Information Available from Other Technologies

As further discussed below, we may use information derived from other standard Internet technologies to the extent you have not opted out of same, such as cookies, pixels, and web beacons.  These technologies will provide us with additional information about your use of the Internet, including websites visited by you, the time and dates of such visits, the types of content you interact with, and your interactions with online advertising.

Information Available from Third Parties

Certain third parties with which we have a relationship, including service providers, affiliates, partners, advertisers and providers of Third Party Offerings may make information about you available to us and such information may either be Personal Information or Non-Personal Information.  The nature of and means by which these third parties gather this information is subject to the privacy policies of the applicable third party.

Section 4. How We Use Your Information 

Your Information that we have collected and/or is otherwise obtained by us is used by us for a variety of reasons, including the provision and improvement of our Products, and to assist our service providers, affiliates, partners, advertisers and providers of Third Party Offerings in providing their own products and services, as well as assisting us with the provision of our Products and advertising the goods and services of others on or through our Products or on other applications, websites, and/or extensions. 

Specifically, Your Information will be used:

When utilizing Your Information for any of the foregoing purposes and other uses of Your Information for legitimate business purposes, we may combine your Personal Information with Non-Personal Information and other information we may obtain from third parties.  We will treat such combined information as Personal Information.

We retain information related to the searches you perform utilizing our search functionality, including search terms you enter, however we do not combine such information with any Personal Information, and we retain such information solely to ensure that our search functionality is performing correctly, to comply with applicable law, and to ensure that our search services provider is complying with its contractual requirements with us.  Your Information pertaining to searches performed utilizing our search functionality is never used by us for ad targeting, retargeting, audience creation or any other similar ancillary purpose not directly related to the core functionality of our search and discovery Apps.

Section 5.  How We Share Your Information

We do not share Personal Information about our users, including you, with companies, organizations or individuals outside of the Company and its affiliated entities, except in those circumstances noted in this Privacy Policy.  When transferring your information, we comply with all applicable privacy laws. 

As set forth in our Terms, we disclaim and shall have no liability or obligation in connection with any third party actions or omissions concerning your information, including your Personal Information, even if such information was obtained from us in accordance with this Privacy Policy.  You are encouraged to contact the applicable third party if you experience any issues with respect to such third party’s use of your information.  

We may share Your Information, including your Personal Information,  (i) with our Affiliates, (ii) to prevent fraud or illegal activities, (iv) to facilitate the function of Third Party Offerings, (v) as required by applicable law, (vi) in connection with a sale or merger of us with another party, and/or (vii) to advertisers and advertising networks we may work with from time to time. As used herein, “Affiliates” includes our parent company and entities under common ownership or control of our ultimate parent company.

We may share Your Information, including your Personal Information to the extent necessary to protect the safety, rights, or property of us, our users, or others, including our business partners and/or to investigate, prevent, or respond to suspected illegal or fraudulent activity.  To the extent that law enforcement authorities, courts, or regulators, request information or we are otherwise required to disclose information to comply with the law or to meet national security or law enforcement requirements, we may disclose any information we have about our users, including you.  We may disclose information collected about our users, including Your Information, in connection with the protection and/or exercise of our legal rights and interests.

In connection with the provision of our Products, we often partner with third parties and in such cases, we may share Your Information, including your Personal Information, to the extent necessary for them to assist us in fulfilling the Products or providing their own Third Party Offerings.  We have entered into contracts with these third parties, including vendors, business partners and service providers or have otherwise taken steps to prohibit or limit them from sharing Your Information, except in accordance with applicable law and/or as necessary to perform on our behalf.  Information about you that such third parties gather as a result of your use of their Third Party Offerings, including without limitation our search functionality, is subject to the applicable third party’s terms of use and privacy policy. 

In connection with a sale or merger of our business or parts thereof pertaining to our Products and/or Your Information (e.g., a sale, merger, or other transfer of assets), or in connection with a corporate restructuring, we also reserve the right to transfer your Personal Information to a third party.

Finally, many of our Products are supported by advertising that appears on or through our Products.  We reserve the right to share Your Information with the advertisers and advertising networks we work with for these purposes.  These companies may also collect information about you, including Personal Information and Non-Personal Information, in connection with your use our Products and any of their Third Party Offerings incorporated into such Products. They also may use cookies and other technologies to collect this information when you visit our site as described below.  Information about you that such advertisers and advertising networks gather about you in connection with your use of our Products is subject to the applicable terms of use and privacy policy of such advertisers and advertising networks. 

Section 6. Privacy Practices of Third Parties

In connection with your use of our Products, it may be necessary or desirable for you to provide Your Information, including Personal Information, to third parties, such as providers of Third Party Offerings, or to download certain software from such third parties. We disclaim all liability and assume no responsibility for the privacy practices of third parties, or the contents of any software downloaded from them.  While applicable law obligates third parties engaged by and/or working with us to protect the privacy of certain types of data, we assume no responsibility for the actions or omissions of these third parties, whether they receive such information from us directly or otherwise.  You should direct any questions you have about such third parties’ privacy practices and/or software directly to such third parties.

Section 7. Cookies and Tracking Technologies

We may send your computer or mobile device a cookie or pixel or beacon or other technology that uniquely identifies your browser in connection with the use of our Products. A “cookie” is a small file containing your preferences that is sent to your browser and sent back by your browser each time your browser accesses our servers.  For purposes of this Privacy Policy, we use the term “cookies” to refer to cookies and all such similar technologies that collect information automatically when you are using our Products.  We use cookies and the data derived from such cookies to improve the quality of our Products and your use of those Products, such as to deliver our Products and Product Content in your language of choice, to filter results and deliver the Products in accordance with your preferences, and to analyze your interaction with our Products.  For example, we track user trends and patterns of how people search.  The cookies we use can only be read by the server that placed them there.  Many browsers are set up to accept cookies unless the user changes the settings for cookies.  By properly setting your preferences in your browser, you can control which and what types of cookies are downloaded from the Products. While you may choose to opt out of receiving cookies, our Products may not function correctly without cookies.  You can review more information about cookies and how to control and delete cookies in various browsers, such as Chrome, Safari, Internet Explorer and others, please visit http://www.aboutads.info/consumers/.

In some cases, we may utilize web analytics companies to assist us in measuring the effectiveness of our Products.  In order to do so, we also allow these third parties to include their own cookies on the Products. Information collected by these web analytics companies from Web beacons and cookies includes click-throughs by users and other similar information. This information is used by us to improve our Products, including by understanding overall user preferences, click-through rates, means to improve our Products, and the types of offers that are of most interest to our users. Although this information is collected by third parties, it is done on our behalf and we retain control over the use of such information.

You can “opt-out” of receiving cookies from certain of our ad serving partners.  For more information on how to do so, please visit: http://www.networkadvertising.org/managing/opt_out.asp

Section 8. Information Retention

Unless a longer retention period is required to comply with law or a legal request, we generally retain information collected about you only as long as is necessary for us to fulfill our business purposes.  Nevertheless, we may, in certain circumstances, 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 9. Data Protection

In connection with our efforts to protect Your Information against loss, misuse, unauthorized access, disclosure, and alteration, we maintain technical, physical, and administrative security measures designed to provide reasonable security for the information we collect and retain, including Your Information. The security measures include the use of firewalls, data encryption, physical access controls to data centers we use, and information access authorization controls. Even given the foregoing precautions we take to prevent possible data breaches in our Products and databases, we cannot guarantee that Your Information will remain completely secure. There can be no assurance that unauthorized hacking, access, data loss, or other breaches will never occur and disclaim all liability in connection with any such activities.  Accordingly, as set forth in our Terms, your use of our Products is at your own risk. Notwithstanding our dedication to securing our systems and Products, you remain responsible for securing and maintaining the privacy of your password, if any, used in connection with your use of our Products. You should protect your Personal Information when you are on the Internet, including making sure you use a secure Internet browser.

Section 10.  Age Restriction

Our Products are not directed to children under the age of 13 (under 16 in the EEA).  While we do not knowingly collect information, including Personal Information, from children under the age of 13 (under 16 in the EEA), in the event that we obtain actual knowledge that we have collected Personal Information from a child under the age of 13 (under 16 in the EEA), we will promptly delete it, unless we are legally obligated to retain such data. We request that you contact us immediately if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13 (under 16 in the EEA).  Additionally, we comply with the Children’s Online Privacy Protection Act; for more information the Act and children’s privacy, please visit http://www.ftc.gov/privacy/coppafaqs.shtm.

Section 11. International Usage and Data Transfers

We make no representation and/or warranty that our Products are appropriate, legal or available for use in any particular jurisdiction. Those who choose to access the Products 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 Products, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion.

If you live outside the United States, you are hereby notified that the Company will transfer your Personal Information to countries other than the one in which you live. In particular, your Personal Information will be transferred to and processed in the United States where many of our central databases operate. By using our Products, you are consenting to such cross-border data transfers of your Personal Data, as set forth in these Privacy Practices. By using the Products, you consent to your Personal Information being collected, processed and transferred as set forth in these Privacy Practices and U.S. law and you acknowledge that the data protection and other laws of other countries, such as the United States, may provide a less comprehensive or protective standard of protection than those in your country. The Company has entered into European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our users in the European Union.

Section 12. Your Rights Generally

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 gdpr@positionmobile.ky.  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 (“GDPR”), 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 gdpr@positionmobile.ky.

Section 13.  EEA Data Privacy Rights

European Economic Area residents have the right to restrict the Company’s use of your Personal Information and lodge a complaint with your local data protection authorities, subject to applicable law. If you are a resident of the European Economic Area and believe we maintain your Personal Information within the scope of the GDPR, you may direct questions or complaints to us at gdpr@positionmobile.ky.

Section 14. California Data Privacy Rights

Under California Civil Code Section 1798.83, which is also known as the “Shine The Light” law, users who are California residents may request from us a list of the Personal Information (if any) that we have disclosed to third parties for direct marketing purposes during in the preceding calendar year, this includes the names and addresses of such third parties. Requests may be made only one time per year. These requests are free of charge. To make a request, please contact us at ccpa@positionmobile.ky  and note that we are not able to accept requests through the telephone, mail or by facsimile.  We cannot be responsible for notices that are not labeled or sent properly or that do not have complete information. In the body of such request, you must put the statement “Your California Privacy Rights”, as well as your name, street address, city, state and zip code and you must provide enough information for us to determine if this applies to you. Additionally, you must attest to the fact that you are a California resident and provide a current California address.

If you are a resident of California, you have certain additional rights under the California Consumer Privacy Act of 2018 (CCPA), including the right:

The request for information can be sent to us at the following address:

Position Mobile Ltd SEZC

Address: PO Box 10008, Willow House, Cricket Square,

Grand Cayman KY1-1001, Cayman Islands

Email: ccpa@positionmobile.ky

Toll Free Number: 800-392-2332

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.

We will respond to your request within 45 days and will include the categories of third parties to which we have sold data about you.  For more information on why we have collected data about you, please see the rest of this Privacy Policy and our Terms.

To opt-out of Position Mobile 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 ccpa@positionmobile.ky.

Section 15. Updates and Amendment to this Privacy Policy

We reserve the right to update this Privacy Policy at any time and for any reason by posting a revised version of this Privacy Policy on the Products and/or in accordance with the other methods established in the Terms of Service. Your continued use of the Products after any such update constitutes your unconditional and binding acceptance of these Privacy Practices, including any updates, amendments, revisions, alterations, modifications and/or supplements that we make from time to time in accordance with the provisions of hereof.

You are encouraged to periodically review this Privacy Policy for updates and to ensure that you are familiar with its terms.  If you do not agree to this Privacy Policy, you should immediately discontinue accessing or using the Products. This Privacy Policy is not applicable to Third Party Offerings or other third party services available on or through the Products.   

Section 16. Contact Us

If you have questions about this Privacy Policy, or if you would like access to the Personal Information we may have about you in our files, to correct, update or to have us delete it, or if you would like to notify us of your choice to opt-out of any sharing of your Personal Information, please contact us at support@positionmobile.ky.   For additional information to assist with protecting your data privacy, you may visit http://www.netcoalition.com and http://www.privacyalliance.org.