Infillion Privacy Policy

1. INTRODUCTION

This Privacy Policy applies globally to all collection of personal information, including applications, websites (including the Infillion.com website referred to herein as the “Site”), and the online, connected tv and mobile advertising and data services (collectively, the “Services”) offered by Infillion and its affiliates (“Infillion” or “we”). We developed this Privacy Policy to describe how we collect, use and disclose information from and about you. If you do not agree to every provision of this Privacy Policy and the related terms of service, you should not access or use the Sites or the Services.

This Site and the Services offered by Infillion are for a general audience, are not targeted to children, and we do not knowingly collect personal information from children under 13 years of age.

This Privacy Policy applies to Infillion’s collection and use of your Personal Data.
Personal Data includes data identifiers such as:

• Your first and last name;
• Email address;
• Unique online identifiers (e.g., cookie IDs);
• Device identifiers (e.g., IDs for mobile advertising); and
• Location data (e.g., latitude and longitude).

Data that does not contain any information that can be used to identify you or has otherwise been anonymized or aggregated is considered “Non-Personal Data.”

2. COLLECTION OF INFORMATION

Infillion collects data directly from you when you provide it to us, automatically as you navigate through the Site, or we receive it from our third parties as part of the Services. Infillion may collect the following information from and about you:

Site Contact Information. The information you may submit to the Site, for example, to obtain information about our services. Contact information may include personal identifiers, for example, name and email address.

Site Activity Information. When you access and interact with the Site, Infillion and our service providers may collect certain information about those visits, including internet or other similar network activity. For example, in order to permit your connection to the Site, our servers receive and record information about your computer, device, and browser, including potentially your IP address, browser type, authentication identifiers, and other software or hardware information. If you access the Site from a mobile or other device, we may collect a unique device identifier assigned to that device, geolocation data, or other transactional information for that device in order to provide the Site to it.

Cookies and other tracking technologies (such as browser cookies or pixels), which are comprised of small bits of data that often include a de-identified or anonymous unique identifier may also be used. Websites, apps and other services send this data to your browser when you first request a web page and then store the data on your computer or other device so the website, app or other service can access information when you make subsequent requests for pages from that website, app or other service. These technologies may also be used to collect and store information about your usage of the Site, such as pages you have visited, the videos and other content you have viewed and advertisements you have seen. Cookies and other tracking technologies may also be used by us or by our service providers to collect and store information on your use of other companies’ websites or services, such as sites you visit and materials you view. We may merge this with other data we collect about you from third parties to assist us in our ability to provide the Site and our Services, including, without limitation, to advertise and provide content to you.

Third parties that provide services to Infillion, such as allowing you to share content or tracking aggregate Site usage statistics, may also use these technologies to collect similar information when you use the Site or third party services. Infillion does not control these third party technologies and their use is governed by the privacy policies of third parties using such technologies.

Data From Third Parties. We also receive other data (e.g., demographic information and digital identifiers) from third parties or through analytical techniques that we combine with the data we collect or derive through the Services. We also may receive data from third parties including:

• Business Partners, Developers & Enterprise Customers: This includes third parties who create and deliver experiences using our services, such as the incorporation of our technology (i.e., SDK or APIs) into their apps and websites. In some cases, these third parties may license data to us.
• Data Suppliers and/or Brokers and Advertising Networks: This includes third parties who provide us commercially available data, including demographic data, data about how you interact with a third party’s websites, apps, smart TVs and streaming devices, device data (including mobile device and advertising identifiers, such as Apple IDFA or Google Advertising ID, and location data), and information from cookies, pixels and other similar technologies.
• Infillion Service Providers: This includes third parties who specialize in providing enterprise data, analytics and software as a service. This data tends to be aggregated, pseudonymized or otherwise de-identified.

Information from Other Sources. We also combine and bundle data collected from these different sources, as well as from Infillion affiliates, and create inferences in order to deliver, maintain, and personalize our services, and to operate our business. You can learn more about Infillion’s data collection, including categories, examples and sources, in the chart below.

Data Category	Data Examples	Data Source
Identifiers / Contact Data (including personal information categories listed in the California Customer Records statute)	Name, email address, phone number, date of birth, address, and other similar contact data.	You Choose to Provide
Demographic Data (including protected classification characteristics under the law)	Gender, age, preferred language, income brackets, occupation, educational status, marital status or other similar information about you.	You Choose to Provide; Data From Third Parties
Geolocation Data	If you opt-in to sharing your precise or approximate location, we receive data about your location whenever you use apps or visit websites incorporating our services.	You Choose to Provide
Internet and Other Network Activity Data	Internet and other electronic network activity data, or data regarding your interaction with websites or advertisements (or those of third parties), and viewing information connected TVs. This data may come from cookies, pixels, web beacons, and/or other technologies. You can control certain types of cookies through your browser settings or other tools.	Automatically Collected; Data From Third Parties
Device Data & Identifiers	Unique device identifiers (e.g., mobile device advertising identifiers such as Apple IDFA or Google Advertising ID), or connected/smart TV or streaming device identifiers, device model, operating system and version, sensor data, language, and wireless network, device name, types of mobile apps installed, or other identifiers such as hashed email addresses.	Automatically Collected Data From Third Parties
Inferences drawn from other personal information	Profiles that reflect a person’s preferences characteristics, predispositions, behavior, attitudes	You Choose to Provide; Automatically Collected; Data From Third Parties
Sensitive personal information	Precise geolocation when opted-in	You Choose to Provide

When we collect data, we rely on several legal bases, these include:

• Contract Performance. When the processing is necessary to perform our contract with you.
• Legitimate Interests. When the processing is necessary for our legitimate business interests (or those of our enterprise customers).
• Consent. When you have given us your consent, including as described in this Privacy Policy.
• Legal Obligation. When we have a legal obligation to do so, as described in this Privacy Policy.

3. USE AND SHARING

We may use the personal information and other information we collect from and about you for the following purposes:

To provide and manage the Site. Infillion and our service providers use the information we collect from and about you to provide the Site and features to you, including, for example, to measure and improve the Site and its features. We may also use aggregated or anonymous data about your use of and activity on the Site to assist us in this regard.

To allow service providers to assist us in providing and managing the Site. Infillion may make the information we collect from and about you available to certain third-party service providers, such as contractors, analytics and other measurement companies, agents or sponsors, who help us analyze and understand your use of the Site and manage and/or provide the Site.

To contact you. Infillion may periodically send promotional materials or notifications related to the Site to the email address you may have provided to us. If you want to stop receiving such promotional materials, please send an email to privacy @ infillion.com or unsubscribe through the designated options in the materials or notifications.

 Product & Service Development. We conduct data analytics and use automated processing, artificial intelligence and machine learning to support internal research, create new products and services, improve functionality of existing products and services, and develop new features such as those developed to enhance security and protect privacy. We use your data, along with inferences that we derive from your data, to offer products and services to developers, our partners and enterprise customers. These product and service offerings include the following:

• Visits: When you opt-in to the collection and sharing of geolocation data from your mobile device, we use that data to create an inferred visit to a public location (“Visits”).
• Audiences (Segments): Using our Visits, along with inferences about your interests, location and other demographics that we derive from the data we have about you, we create “Audiences.” Audiences are then used to send you advertisements tailored to your interests.
• Points of Interest (POI): POI data relates to physical places (restaurants, shops, airports, hotels, etc.) and is used to identify and provide context to points of interest worldwide. This data is typically Non-Personal Data.

Sharing with Your Consent or at Your Direction. We share your personal data with your consent or as necessary to complete any transaction or provide any product you have requested or authorized.

Sharing with Affiliates. We share data with other Infillion affiliates for the purposes outlined in this Privacy Policy.

Sharing with Service Providers & for Business Purposes. We share your data with service providers that perform services on our behalf, such as cloud storage, IT services, marketing, analytics and search engine and other software services.

Sharing with Enterprise Customers. We share data with enterprise customers that, for example, may use “Visits” combined with data that they collect to understand movement patterns to determine where to open a physical store, to conduct analytics, to serve targeted ads, and to determine whether an online or offline advertisement you were exposed to resulted in a visit to a physical store. Under certain privacy and data protection laws, this activity may be considered a “sale” of personal data.

Sharing with Advertising Partners. We may share data such as your mobile advertising identifier with advertising partners (including the ad networks, ad-serving companies and other service providers they may use) so that they may recognize your devices and deliver interest-based content and advertisements to you. Under certain privacy and data protection laws, this activity may be considered a “sale” of personal data or a “share” of personal data for cross-context behavioral advertising.

Sharing for Corporate Transactions. We may also share data as part or in anticipation of a business sale, merger, consolidation, investment, change in control, transfer of substantial corporate assets, reorganization, liquidation, or similar business transaction or corporate event.

Disclosures of Sensitive Personal Information.. We do not use or disclose sensitive personal information for purposes other than those specified in the CCPA.

4. SECURITY

Infillion uses commercially reasonable administrative, technical, personnel and physical measures to safeguard information in its possession against accidental loss, theft and unauthorized access, use, disclosure or modification. Although we do our best to protect your information, no one can guarantee the complete safety of your information.

5. USER CHOICES, ACCESS AND CONTROL

We strive to provide you with choices regarding the personal information you provide to us through the Site or our Services. We have created mechanisms to provide you with the following control over your information:

• Access, Correction, or Deletion.If you would like to access, review, correct, update, suppress, delete, or otherwise limit our use of your personal information, including sensitive personal information, please fill out this form or contact us via email at privacy @ infillion.com. In your request, please include your name and specify clearly what information you would like to access, change, update and/or whether you would like to have your personal information suppressed, limited, or deleted from our database, or if you have other questions about your personal information.
• Tracking Technologies and Advertising. Most browsers are initially set to accept cookies, but you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information. Users can manage the use of Flash technologies, with the Flash management tools available at Adobe’s website. Please note that by blocking any or all cookies you may not have access to certain features, content or personalization available through the Site.
• Promotional Offers from Infillion. If you do not wish to have your email address or other contact information used by Infillion to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to privacy @ infillion.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to Infillion as a result of a product purchase, warranty registration, product service experience or other transactions.

6. DATA RETENTION

To the extent permitted by applicable law, we keep the personal data you provide for the purposes indicated in this Privacy Policy for the duration of our legitimate business purposes or to comply with the applicable statute of limitations periods and other applicable laws or legal considerations. You may ask us to delete that information by following the instructions in “Access, Correction, or Deletion” section.

The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you are a client with us or keep using our services) and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise;
• Whether there is a legal or ethical obligation to which we are subject (for example, certain laws require us to keep records for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

7. OTHER IMPORTANT INFORMATION

Means of Notice and Choice. This Privacy Policy is the primary means by which Infillion provides you with notice and choice regarding its collection and use of your personal information.

Updates to Privacy Policy.Infillion may modify this Privacy Policy from time to time. Please look at the Last Reviewed Date at the top of this Privacy Policy to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Site.

Location of Data. The Site and our Services are hosted in and managed from the United States. If you are a user located outside the United States, you understand and consent to having any personal information transferred to and processed in the United States. United States data protection and other relevant laws may not be the same as those in your jurisdiction. This includes the use of cookies and other tracking technologies as described above. As a result, please read this Privacy Policy with care.

Linked Services. The Site or Services may also link, or be linked, to sites or services operated by unaffiliated companies, and may carry advertisements or offer content, functionality, games, newsletters, contests or sweepstakes, or applications developed and maintained by unaffiliated companies. Infillion is not responsible for the privacy practices of unaffiliated companies, and once you leave the Site via a link, enable an unaffiliated service or click an advertisement you should check the applicable privacy policy of the unaffiliated service.

In addition, Infillion is not responsible for the privacy or data security practices of other organizations, including but not limited to any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including in connection with any information you disclose to other organizations through or in connection with the Site or Services.

Special Categories of Information under the GDPR.  We ask that you not send us, and you not disclose, any special categories of personal information under the GDPR (such as government identifiers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Site or otherwise.

8. CALIFORNIA RIGHTS

California residents have certain rights with respect to the personal information collected by businesses. If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:

• The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell about you, the categories of sources from which we collected your personal information, our purposes for collecting or selling your personal information, the categories of your personal information that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have shared personal information;
• The right to request that we delete the personal information we have collected from you or maintain about you.
• The right to correct any inaccurate personal information we may have collected from you or maintain about you.
• The right to opt out of our sale(s) of your personal information or sharing of your personal information for cross-context behavioral marketing purposes. Please note that if you opt out of certain types of sales or sharing, we will be unable to provide you with the services that rely on such sales or sharing.
• The right to limit the use of sensitive personal information.
• The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

To exercise any of the above rights, please contact us and submit the required verifying information by filling out this form or contacting us via email at privacy @ infillion.com. Only you or an authorized agent may make a request related to your personal information. To designate an authorized agent to make a request on your behalf, please provide us with a power of attorney or other legally binding written document signed by you and identifying your agent via email to privacy @ infillion.com. We may also verify the identity of your designated agent.

Shine the Light. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy @ infillion.com.

9. CONTACT US

If you have questions about this Privacy Policy, please contact us via email at privacy @ infillion.com or you may contact us by mail at: Office of the General Counsel at Infillion, 382 NE 191st Street, PMB 62545, Miami, Florida, 33179-3899.