Last updated: Dec 27, 2022
This Privacy Policy describes how Placer Labs, Inc. (“Placer” or “we”) collects, stores, uses and discloses information about individuals who use mobile apps developed and operated by third parties that have integrated our software development kit (the “SDK”), from which Placer receives or collects certain information and data (such individuals are referred to herein as “Consumers”).
This Privacy Policy (Consumers) (this “Privacy Policy”) is incorporated into and is subject to our Terms of Use at https://placer.ai/terms-of-service (the “Terms of Use”). By using the SDK as a Consumer, you agree to Placer’s collection, storage, use and disclosure of your information as described in this Privacy Policy. If you disagree with anything in this Privacy Policy, please do not use the SDK.
Your Rights
We respect your privacy rights and provide you with reasonable access and rights to the Personal Data, as this term is referred to for individuals located in the European Economic Area (EEA), pursuant to the European Directives 95/46/EC and 2002/58/EC (EU General Data Protection Regulations Legislation, also known as GDPR), that you may have provided through your use of the SDK. If you live in one of those countries, and wish to access, amend, delete, or transfer any Personal Data we hold about you, you may contact us as set forth in the “How to Contact Us” section in the Privacy Policy.
You may update, correct, or delete your Personal Data and preferences at any time by request to us. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
You may decline to disclose certain Personal Data to us, in which case we may not be able to provide to you some of the features and functionality of the SDK or our services.
At any time, you may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law. If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact us as set forth in the “How to Contact Us” section in the Privacy Policy. You also have a right to lodge a complaint with data protection authorities.
Legal Basis for Processing Personal Data;Retention
Placer will only collect and process Personal Data when we have lawful bases for doing so. These lawful bases include when you provide consent, when we have a contractual obligation to collect or process your Personal Data, and when we have a legitimate interest in processing your Personal Data.
Transfers
Where we transfer your Personal Data outside the EEA, we rely on approved standard EEA Model Clauses so these transfers are conducted in accordance with applicable laws and using adequate and appropriate safeguards.
Introduction; “Personal Information” under the CCPA
This Appendix B supplements the information contained in our Privacy Policy above and applies solely to those of you who reside in the State of California. We adopt this supplemental notice to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (the “CCPA”). Any terms defined in the CCPA have the same meaning when used in this Appendix B, unless otherwise noted.Under the CCPA, “personal information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.Personal information does not include:
Information We Collect
The table below sets forth the categories of personal information that we have collected within the last twelve (12) months:
Categories of Sources from Which Personal Information is Collected
We obtain the personal information of Consumers listed above from the following categories of sources:
Business or Commercial Purpose Which Personal Information Will Be Used
Please note that Placer does not disclose personal information to any third parties, unless explicitly permitted in our Privacy Policy or with your consent.
As described in more details in Section 4 of our Privacy Policy:
Disclosing Personal Information
As described in more detail in Section 5 of our Privacy Policy, we may disclose personal information with service providers, to comply with laws, to protect our legal rights, and in corporate reorganizations. When appropriate, we enter into contracts that describe the purpose of the disclosure and require the recipient to keep that personal information confidential.
No Sale or Sharing of Personal Information
We do not sell personal information to, or share personal information with third parties. As used here, to “sell” means to disclose personal information to third parties for monetary or other valuable consideration, and “share” means to disclose personal information to third parties for cross-context behavioral advertising. These terms do not include, for example, the transfer of personal information as an asset that is part of a merger or other disposition of all or any portion of our business.
Rights under the CCPA
Access to Specific Information; Deletion; Correction
If you are a California resident, you have the right to:
Exercising Your Rights
To request access to your personal information or request deletion, please submit a verifiable request through one of the following methods:
Only you or a person authorized to act on your behalf may make a consumer request related to your personal information.
You may only request a copy of your data twice within any 12-month period. The request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
Our goal is to respond to a verifiable request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Any disclosures we provide will cover only the 12-month period preceding the request. If applicable, the response we provide will also explain the reasons we cannot comply with the request. We will provide your personal information in a format that is readily usable and should allow you to transmit the information without hindrance.We will not charge a fee to process or respond to your request unless it is excessive or repetitive. If we determine that the request warrants a fee, we will provide you with the basis for that decision and a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by the CCPA, we will not, because of your exercise of such rights:
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website.
Contact Information
If you have any questions or comments about this notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at: