Privacy

REVEAL MOBILE PRIVACY POLICY

Last Updated June 21, 2018

Reveal Mobile, Inc. (“Reveal Mobile,” “we” or “us”), the builder of the Reveal Mobile product and website, is committed to protecting your privacy. We know that you care about how information about you is used and shared, and we appreciate your trust that we will use that information carefully and sensibly in accordance with this Privacy Policy.

Please read this Privacy Policy carefully so that you understand our privacy practices.

The Reveal Mobile Product (“Mobile Product”) provides a software development kit (SDK) (the “Mobile Product”) to mobile application companies and publishers (our “Customers”) and also receives data directly from Customers through secure server-to-server feeds.  The Mobile Product can be incorporated into mobile applications and collects data about mobile devices.

This Privacy Policy governs our collection, sharing and use of non-personally identifiable information (“Non Personal Information) or Personally Identifiable Information through mobile applications using the Mobile Product.  This Privacy Policy also governs the personally identifiable information (“Personal Information”) collected by Reveal Mobile through our websites at www.revealmobile.com (the “Website”).  Reveal Mobile does not intentionally collect or process the personal data of individuals in the European Economic Area unless you expressly provide information to us through the Website.  If you are visiting the Website from the European Economic Area or are using the Mobile Product within the European Economic Area, in addition to the other terms of this Privacy Policy, please see the section below entitled Individual Rights on Data Collection for European Economic Area / European Union (EU).

Consent

By expressly acknowledging this Privacy Policy, using the Website and/or continuing to use the Mobile Product and opting in to data collection, you are expressly consenting to the collection and use of data as set forth in this Privacy Policy.  If you do not agree to the terms of this Privacy Policy, you should not install any mobile application which utilizes the Mobile Product and/or should deinstall the Mobile Product immediately, or you may opt-out of data collection through one of the methods listed below. Your use of the Mobile Product shall constitute your acceptance of the terms of this Privacy Policy.

By visiting our Websites, you agree to the terms of this Privacy Policy with respect to your use of our Websites and any Personal Information that you may provide to us through the Website. This Privacy Policy will govern our collection, sharing and use of your Personal Information and Non Personal Information. If you do not agree to the terms of this Privacy Policy, you should not use our Website. Your use of the Websites shall constitute your acceptance of the terms of this Privacy Policy.

This Privacy Policy only relates to Reveal Mobile’s collection and use of information through the Mobile Product and Website and does not govern the collection and use of information directly by our Customers.  Before sharing any information or data with any Customer of Reveal Mobile, you should review the privacy policy of the Customer.

In order for Reveal Mobile to stay current with industry best practices and regulations on privacy and security, we belong to the Mobile Marketing Association’s Privacy Committee and the Internet Advertising Bureau’s Public Policy Committee. We’re also members of the consumer privacy trade group the Future of Privacy Forum, a nonprofit organization that serves as a catalyst for privacy leadership and scholarship, advancing principled data practices in support of emerging technologies.

Reveal Mobile is a member of the Network Advertising Initiative (NAI). Reveal Mobile undergoes an annual NAI compliance review and adheres to the NAI’s Code of Conduct. To learn more about the NAI or how to opt out of receiving targeted advertising from other third party services that belong to the NAI, please visit: http://www.networkadvertising.org/mobile-choices

Data We Collect – Mobile Product

Our Customers integrate our Mobile Product into their mobile applications or send it to us directly via a secured server-to-service transfer.  This enables us to receive the information described below, consistent with the authorizations you have provided, concerning the mobile device and/or the use of the mobile application.   

  • Precise Location Data –  By opting in to share your location data, the Mobile Product allows us to collect information regarding your location, or the location of your device, by using GPS coordinates provided by your mobile device. The Mobile Product will also indicate if you come within proximity of a Bluetooth Low Energy (BLE) device such as a beacon, and the amount of time you spend in proximity to the beacon.  The GPS coordinates and beacon information are collectively referred to herein as “Location Data.” When any of our Mobile Products is open on your mobile device, we periodically receive Location Data. Some of our Customers may also enable collection of background location data when the app is not in use, which enables us to also receive this Location Data. Most GPS-enabled mobile devices can identify a user’s location to within less than 50 feet.  For some U.S. based devices that share location, we are able to infer a home or work location based upon frequent usage patterns. Reveal Mobile stores Location Data, and Location Data is passed through to our Customers, service providers and partners, including ad networks, ad serving companies and third party information providers, as described below.
  • Automatically Collected Information; Other Non-Personally Identifiable Information.  When you opt-in to data sharing while using any of our Mobile Products by agreeing to share location with a Customer’s app, our web server automatically collects limited information about your device. Reveal Mobile logs non-personally-identifiable information including the mobile advertising ID (IDFA / AdID), IP address, SSID/BSSID, the type of mobile device you use, the IP address of your mobile device, and your mobile operating system. We do not store IP address or SSID/BSSID data for residents of the EU. If you opt-out of location sharing, the Mobile Product sends no information to Reveal Mobile.
  • Aggregate Information Used to Serve and Target Ads, Interest-Based Advertising: We may aggregate the data we collect from users of our Mobile Products and provide this to our Customers and/or third parties to target ads on other mobile applications. When we aggregate your information, no specific personal information is included, and you cannot be identified from this aggregate information.
  • International Data Collection – Reveal Mobile stores and processes information collected from our SDK and data feeds in the United States. For people residing outside of the United States, by using mobile apps with our SDK inside, you are agreeing to the transfer of information to the U.S. and the use of your data as identified in this Privacy Policy. You should be aware that the U.S. rules and regulations governing collection and use of data may differ from the country in which you currently reside.
Data We Collect – Website
  • Information you Provide. You are not required to register or provide any Personal Information in order to browse our Website and learn more about our company, our products and our technology. However, if you request or download any white papers or other information or sign up for our newsletter, you will be required to provide certain limited Personal Information such as your name, email and telephone number. We will use such information to confirm and deliver your request to you. We do not share this Personal Information with any third party, other than our service providers if necessary to fulfill your request, or as otherwise described in this Privacy Policy. For example, if you sign-up for our newsletter, we may provide your Personal Information to our service provider that manages and delivers our newsletters.
  • Browser-Level Information: When you browse our Website, our web server automatically collects limited information about your computer configuration or device or, such as the type of browser software you use and the operating system you’re running and your IP address.
  • Reveal Mobile logs non-personally-identifiable information including IP address, profile information, 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, from users and visitors to the Website and the type of mobile device you use, the IP address of your mobile device, your mobile operating system, and the type of mobile browsers you use. This data is used to manage our Website, including diagnosing problems with our Website, track usage and improve the Website. User IP addresses are recorded for security and monitoring purposes.
  • Cookies: We also use “cookies” to track which pages of our Website you visit. We use the services of an independent company to help us measure the effectiveness of how visitors use our Website. To do this, we use Web beacons and cookies provided by our marketing company. The type of information we collect include pages visited, videos viewed, etc. This information helps us learn things like what pages are most attractive to our visitors, which of our products most interest our customers, and what kinds of offers our customers like to see. Because cookies are stored on your computer or device, not on our site, you can set your browser to decline cookies and can delete them from your computer or device.
Privacy of Children

Protecting the privacy of children is especially important. For that reason, Reveal Mobile does not knowingly collect any Personal Information from anyone under the age of 13. In no other way do we knowingly collect or maintain personally identifiable information from persons under 13 years of age, and no part of our Mobile Product is directed to persons under 13. If Reveal Mobile learns that Personal Information of persons under 13 years of age has been collected through its Website or a Mobile Product, then Reveal Mobile will take the appropriate steps to delete this information and to flag the device to prevent any future data collection.

Disclosure and Sharing of Information and Data Retention

Information about our customers is an important part of our business. We do not rent, sell, or share your Personal Information, including Location Data collected via the Mobile Product or share your Personal Information collected via the Website other than as described in the Privacy Policy, including as follows:

  • We may disclose and/or sell your Location Data to third parties for the purposes of providing targeted advertisements and information our advertising partners believe may be of relevance and interest to you; these third parties include but are not limited to data aggregators, ad networks and ad serving companies, such as Google, Factual, GroundTruth and others.   
  • We may disclose your Personal Information to our service providers who work on behalf of Reveal Mobile, including to provide our Website with services or to fulfill user requests. However, these companies are not allowed to share this information or to use it for their own purposes.
  • For international users, we transfer Personal Data into the United States on the basis of the EU-US Privacy Shield Framework. This data is passed to third parties such as Google, Salesforce, and Mailchimp, and is based upon consent from the end user.
  • We may add additional data to the existing data collected about your device, such as appending non-personally identifiable US Census data to the device.
  • We may disclose non-personally identifiable information, including your IP address and as part of an aggregate data set to third parties for the purposes of providing targeted advertisements and information our advertising partners believe may be of relevance and interest to you.
  • We may disclose your data to comply with legal requirements or to respond to a subpoena, search warrant or other legal process or government request received by Reveal Mobile, whether or not a response is required by applicable law.
  • We may disclose your personal information to enforce our rights in our Mobile Products and/or Website or to protect the rights, property or safety of members of the Reveal Mobile community, our Customers, other visitors to our Mobile Products or Website, the public, or Reveal Mobile and its employees.
  • As our business grows, we may buy or sell various assets. In the event that Reveal Mobile or some or all of our assets are acquired by another company, information about our users may be among the transferred assets.
  • In the event that Reveal Mobile goes through a bankruptcy, reorganization, receivership or similar event, you understand and agree that we may not be able to control how your Personal Information or Location Data collected by us is treated, transferred or used.
  • Please keep in mind that whenever you voluntarily make your Personal Information available for viewing by third parties on any part of our Website, that information can be seen, collected and used by anyone who visits the site. We cannot control and therefore cannot be responsible for any unauthorized third-party use of such information. Please respect the privacy of others by not posting their personal information on our site without their permission.

Reveal Mobile does not retain any European Economic Area/European Union (EU) data from our Mobile Product. Should we receive any EU data either from our SDK or a data feed, that data is immediately discarded and never processed. Reveal Mobile transfers personal data that is provided by end users when they enter this data into our Website for the purposes of receiving marketing collateral or email newsletters. This marketing data is collected and stored by Google, Salesforce, and Mailchimp, and may be retained for so long as it remains useful in connection with sending marketing and sales material.

Unless we receive an opt-out request (as discussed below), Reveal Mobile stores the non-personally identifiable information about your device for up to five years as long as that device remains active within our servers for 180 days. If the device is inactive for a period of greater than 180 days, we purge all data on this device.

If you provide Personal Information to us through our Website, such as signing-up for our newsletter, you may request that we delete such Personal Information from our system, by sending a request to optout@revealmobile.com. We will promptly cease use of any such Personal Information and will remove such Personal Information from our servers in accordance with our standard practices, but within at least two weeks.  Certain non-personally identifiable information relating to your use of the Website may be retained for so long as it remains useful in connection with improving our Website and/or Mobile Product.

All data collected or received by Reveal Mobile is securely stored and processed in the United States.

Data Security

Reveal Mobile has taken steps to protect the confidentiality of the data it collects from users of its Website and Mobile Products. Information we gather on Reveal Mobile is stored within Reveal Mobile controlled databases (or databases hosted on our behalf) on servers maintained in protected environments, and we limit access to such information to Reveal Mobile employees who we believe need to see that information to provide you with services or otherwise do their jobs. However, no physical or electronic security system is impenetrable, and we cannot guarantee the security of our servers or databases, nor can we guarantee that the information that you supply to us won’t be intercepted during transmission over the Internet.

Opt-In Services

Reveal Mobile and the Mobile Product is an opt-in service only. When you download a mobile application that uses the Mobile Product and choose to share your device’s location, you are opting in to this service. Reveal Mobile works closely with our Customers to ensure they provide adequate notification and transparency to their end users about these practices and the appropriate privacy policies. It is the responsibility of our Customers to provide these notifications.

Mobile applications 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 you to accept any permissions that the app asks for before you can install the app.  If you downloaded the app, you’ve opted in. Newer Android phones allow you to opt-in or out of location sharing after downloading the app.

Apple apps allow you to download the app, but then to opt in or out of sharing location, Bluetooth settings, and certain advertising settings on your device’s Settings > General pages.  If you opt-out of any of these after downloading an app using Reveal Mobile, we honor these settings and don’t collect those data points. With the release of iOS 11, Apple made changes to how iOS, the phone’s operating system, handles some permissions such as Bluetooth. To learn more about that, read Apple’s documentation here: https://support.apple.com/en-us/HT208086.

All of the apps with which we work are required to provide access to the information in this Privacy Policy prior to collecting any data and to secure your consent to the collection of your data as set forth herein.

Individual Rights on Data Collection for European Economic Area/European Union (EU)

Effective May 25th, 2018, Reveal Mobile does not offer its goods or services to individuals within the EU and does not collect, process or store any personal data from the European Union market area for the purposes of building segments for interest-based advertising within the Mobile Product. If Reveal Mobile inadvertently receives personal data from within the EU from our Customers, as verified by examining the lat/long coordinates received, Reveal Mobile immediately discards that data and does not store or analyze it.

Reveal Mobile stores personal data that is directly provided by end users when they enter this data into our Website for the purposes of receiving marketing collateral or email newsletters.  When you provide this data, Reveal Mobile will present you with explicit and informed consent to sharing data, and by providing this data you expressly consent to its use as set forth in this Privacy Policy. The data entered into our Website is collected by Reveal Mobile and shared with Google, Salesforce, and Mailchimp in order to provide the requested marketing collateral and e-mail newsletters.

Subject to applicable law, you may have additional rights regarding the processing of your data.

  • The right to access your data, or to request copies of it, subject to verification
  • The right to request corrections to your data
  • The right to request deletion or restriction of your data
  • The right to object to data collection
  • The right to transfer your data to another data controller
  • The right to file a complaint with the appropriate Data Protection Authority regarding the processing of your data

Reveal Mobile contracts with the following firm to serve as our Data Protection Officer and EU Designated Representative:

External Data Protection Officer
ePrivacy GmbH
represented by Prof. Dr. Christoph Bauer
Große Bleichen 21, 20354 Hamburg

For all request concerning the security of your data you can contact our data protection officer at privacy@revealmobile.com.

Opting Out of Data Collection and Access to Your Data

There are numerous ways to opt-out of sharing data with Reveal Mobile.

If you disable ad tracking on your phone or tablet, we no longer collect or store any data about your device. Our product respects the advertising settings on your phone to limit ad tracking.  This also opts your device out of all ad tracking across all of your apps.

You can 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.

You can also email optout@revealmobile.com to determine if we have data on your device. If so, we’ll remove your device(s) from our database within 7 business days or less. You’ll need to provide us with the IDFA (iPhones) or Advertiser ID (Android phones) in order for us to remove your device. We don’t collect any email addresses, names, or phone numbers from mobile apps, so we need this identifier to find your device in our database. This blog post provides helpful tips on how to find your advertising identifier: https://www.mparticle.com/blog/how-to-find-your-mobile-device-identifiers/

To learn more about opt-out choices, we recommend reviewing the Network Advertising Initiative’s article on “Information on Opting-Out on Mobile Devices”: http://www.networkadvertising.org/mobile-choices

If you want to see the data we have stored for your device, email optout@revealmobile.com along with your IDFA and/or AdID.  We’ll then ask for verification of your identity, and then provide you the data, if any, we have stored about your device, and allow you to rectify any errors in any personal data as permitted by applicable law.

EU-US Privacy Shield Framework

Reveal Mobile complies with the EU-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 to the United States.  Reveal Mobile has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Reveal Mobile’s End User and Website Privacy Policy describes the types of personal data collected, the purposes for which it collects and uses personal information, the type or identity of third parties to which it discloses personal information, and the purposes for which it does so, the right of individuals to access their personal data, the choices and means the organization offers individuals for limiting the use and disclosure of their personal data, and the requirement to disclose personal information in response to lawful national security or law enforcement requests. Reveal Mobile is responsible for the processing of the personal information it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Reveal Mobile complies with with Privacy Shield Framework for all transfers of personal data from the EU. Reveal Mobile may be liable under the Privacy Shield Framework if a third party processes personal information in a way inconsistent with the Framework, unless Reveal Mobile proves it is not responsible for the event giving rise to damage.

As it pertains to the personal information received or transferred pursuant to the Privacy Shield Framework, Reveal Mobile is subject to the investigatory and enforcement powers of the Federal Trade Commission with respect to Reveal Mobile’s compliance to the Privacy Shield Framework.

Reveal Mobile commits to refer unresolved Privacy Shield complaints to the EU Data Protection Authorities (DPA). If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit the EU DPA for more information or to file a complaint.  The services of the EU DPA are provided at no cost to you.

Reveal Mobile commits to cooperate with the panel established by the EU data protection authorities and comply with the advice given by the panel with regard to data transferred from the EU.

In compliance with the Privacy Shield Principles, Reveal Mobile commits to resolve complaints about our collection or use of personal information. If your complaint is not resolved, you may have the right, under certain limited conditions, to invoke binding arbitration before the Privacy Shield Panel of the U.S. Department of Commerce.

Residents of the European Union with inquiries or complaints regarding our Privacy Shield policy should first contact Reveal Mobile at:

privacy@revealmobile.com

Brian Handly, CEO
Reveal Mobile, 3344 Hillsborough St, Suite 100, Raleigh, NC 27607

Social Media Sites, Links To Other Sites

We may have pages, accounts or presence on various social networking and media sites or services, such as Facebook, LinkedIn, and Twitter.   Any information you post or provide through such social media sites and services will be subject to the policies of the applicable site or service.

The Website may include advertisements and links to third-parties web sites or service whose privacy policies we do not control. When you access another app or site, use of any information you provide on such site or app, and any information collected by the site operator, is governed by the privacy policy of the operator of the app or site you’ re visiting. If you click through to any of the advertisers on a Mobile Product, the advertiser may also track your device.  We do not have access to or control any information they may contain.

Tracking

We do not track or collect Personal Information about your online activities once you leave our Website.

Changes to Our Privacy Policy

Because the web and Mobile Products are evolving mediums, we may need to change our Privacy Policy at some point in the future, in which case we’ll post the changes to this Privacy Policy on our Website and/or within the applicable Mobile Product and update the Effective Date of the policy to reflect the date of the changes. Unless a material change to the Privacy Policy is made, by continuing to use the Mobile Product after we post any such changes, you accept the Privacy Policy as modified.

Contacting Us with Questions

For more information, or if you have questions about this Privacy Policy, please contact us at privacy@revealmobile.com.   You can download or print a copy of this Privacy Policy at https://revealmobile.com/privacy/, or contact us at privacy@revealmobile.com to request a copy, or write to Brian Handly, CEO, 3344 Hillsborough St, Suite 100, Raleigh, NC 27607