GroundLevel Insights Inc. – Global Privacy Statement
GroundLevel Insights, Inc. (“GLI, “we”, “us”) are committed to protecting and respecting privacy and the protection of information that may be used to identify you directly or indirectly (“Personal Data”). This Statement explains our approach with respect to data we receive from our partners, such as mobile application (“App”) developers and publishers, data aggregation services, and providers of location-supporting technologies (the “Partners”). The technologies utilized by the Partners interact with mobile devices in the physical world through Apps, GPS, mobile device Bluetooth connections, and Wi-Fi connections. In this Statement we also provide information on some of the methods available to individual users of mobile devices (“you” or “user”) to limit the collection of data from or about their mobile devices by the Partners.
In addition to the data provided by our Partners, we receive data through our software development kit (“SDK”) included in Apps of some of our Partners. Some of the data we receive from the Partners or through the SDK may constitute Personal Data under applicable laws.
The data provided by our Partners and the data collected by means of the SDK does not include data that directly identifies you, such as your name, mobile phone number, or your email address.
We process the data provided by the Partners and the data collected by the SDK based on our legitimate interest of providing, improving, and analyzing our location-based products and services and, where appropriate or as required by law, based on your consent that you have provided to our Partners. Please be reminded that you have the right to withdraw your consent at any time. We balance our legitimate interests with the privacy interests of the users of mobile devices and incorporate privacy-enhancing technologies such as data aggregation and data retention limitations into our data processing platform.
We analyze, anonymize and contextualize the data provided by the Partners and the SDK for purposes of providing accurate location intelligence to our clients. This location intelligence can be used for advertising, audience segmentation, people-based movement analytics, improving business decision making by better understanding of customer movement patterns, assisting municipalities in urban planning by enhanced understanding of movement patterns, and similar purposes that utilize location as a tool. The data may also be used for the purpose of improving and analyzing the various services provided by us.
First, please familiarize yourself thoroughly with the privacy policy of any App you download on your mobile device, checking in particular what types of data the App collects from or about your device(s). Do not download an App if you do not feel comfortable with the data collection practices described in the applicable privacy policy. If you have already downloaded such an app, delete it.
All major mobile device operating systems enable the users of mobile devices to control the types of data collected in and through Apps.
i) iOS
Apple instructions on how to control iOS device location settings can be found here: https://support.apple.com/en-us/HT203033
Apple instructions on how to limit ad tracking on iOS devices can be found here: https://support.apple.com/en-us/HT202074
For other privacy-related settings on iOS, please go to Settings from your mobile device’s home screen, and select “Privacy.”
ii) Android
Android instructions on how to control device location settings can be found here: https://support.google.com/nexus/answer/6179507?hl=en&ref_topic=6179522
Android instructions on how to limit ad tracking on Android devices can be found here: https://support.google.com/nexus/answer/3118621?hl=en.
All major mobile device operating systems enable the users of mobile devices to disable Bluetooth from functioning.
i) iOS
You can disable Bluetooth by going to “Settings” from your Device’s home screen; select “Bluetooth”; and turn Bluetooth off.
ii) Android
You can disable Bluetooth by going to the Settings app, then “Wireless and networks,” where you can disable Bluetooth.
We may disclose the data provided by the Partners and the data collected by the SDK with third parties such as advertising networks, advertising publishers, and advertisers, research companies, data brokers, financial institutions, data analytics platforms, in accordance with the terms of the agreements, and only for the purposes of performing such agreements, that we have in place with such third parties. Such disclosures do not include any data that can directly identify a user of a mobile device, such as a name, mobile phone number, or an email address.
As a matter of policy, GLI retains data received from our Partners as long as the data is needed for the purposes described above in Section 3 or as long as required by law.
Finally, unless we are legally required to do otherwise, if you submit a request in accordance with the instruction set out in Section 6 above, we only retain that Advertising ID for purposes of blocking it from further use and disclosure by GLI.
GLI complies with the EU-US Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (Privacy Shield) as set forth by the US Department of Commerce regarding the collection, use, and retention of personal data transferred from the EU and the United Kingdom and/or Switzerland, as applicable to the United States in reliance on Privacy Shield. GLI has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. A violation of our commitment to Privacy Shield may be investigated by the Federal Trade Commission and/or the United States Department of Commerce. If there is any conflict between the policies in this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, to the extent available, please visit https://www.privacyshield.gov.
In compliance with the Privacy Shield Principles, GLI commits to resolve complaints about your privacy and our collection or use of personal data about you. Persons from the EU who have inquiries or complaints regarding this Statement should first contact us via email at: privacy@groundlevelinsights.com.
Under UK and EU GDPR (General Data Protection Regulation), our legal basis for collecting and using your personal data will depend on the type of personal data and how it was collected. Note, at present we don’t work with any personal data, only anonymous, non-identifiable data.
For the purposes of this Privacy Notice we will only be processing your personal data where we have your consent or where we have a legitimate interest to do so. If we process your personal data based on a legitimate interest we will ensure that this processing is not overridden by your rights, such as your right to opt-out, and that we have carried out a balancing test. An example of where we rely on our legitimate interests to process your personal data is to prevent fraudulent advertising and to deliver an advertisement to your device.
If you wish to learn more about the legal basis on which we collect and use your personal data please contact us at privacy@groundlevelinsights.com.
GLI has committed to refer unresolved privacy complaints under the Privacy Shield Principles to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit for more information and to file a complaint.
Additionally, with respect to complaints concerning human resources data that is transferred from the EU to the United States, we have agreed to participate in the dispute resolution procedures of the EU Data Protection Authorities. Contact details for the EU data protection authorities can be found at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. GLI will cooperate with the appropriate EU Data Protection Authorities during investigation and resolution of complaints concerning human resources data that is transferred from the EU to the United States under the Privacy Shield.
These recourse mechanisms are available at no cost to you. Damages may be awarded in accordance with applicable law.
Under certain conditions, if you are not satisfied with the above recourse mechanism, you may be able to invoke binding arbitration.
In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, GLI, Inc. is potentially liable.
Pursuant to the Privacy Shield, GLI remains liable for the transfer of personal data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages.
If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by GLI to third parties for the third parties’ direct marketing purposes. To make such a request, please send an email to privacy@groundlevelinsights.com or write us:
GroundLevel Insights Inc.
1080 Brock Road, Unit # 11, Pickering, ON, L1W3X4
From time to time we may change this Statement. You can tell when changes have been made to the Statement by referring to the “Last Updated” legend on top of this page. Please review this Statement regularly to ensure that you are aware of any changes.