1. Introduction

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.

2. How Does GLI Obtain Data And What Data Do We Obtain?

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 the Partners and the SDK may include:

• IDFA and/or advertising identifier (“Advertising ID”)
• Location of the mobile device expressed as the latitude, altitude, and longitude of the mobile device and the derived identity of the location, such as a fastfood restaurant
• Mobile device operating system and operating system version
• Mobile device make and model
• The name and version of an App
• Other metadata associated with the mobile device, such as network type and IP address
• The category of the App that collected data (i.e. casual gaming, weather, social media)
• GPS horizontal accuracy value
• If the App was in active use or in the background when data was collected
• The speed at which the device was traveling
• If the device was being charged at the time of data collection
• The direction that the device was traveling
• If the device is connected to a WiFi or cellular network
• WiFi SSID (network name) or BSSID (MAC address for the router)
• Nearby SSID or BSSID and the signal strength

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.

3. What Do We Do With Partner-Provided Data And For What Purposes Is It Used?

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.

4. In What Ways Can I Control the Collection of Mobile Device Data? Data Collected Through Apps

a) Privacy Policies

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.

b) Device Settings

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.

Data Collected Via Bluetooth

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.

5. How Does GLI Disclose the Partner-Provided Data to Third Parties?

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.

We may also disclose data provided by our Partners to:

• Our service providers, such as data storage providers;
• Public authorities, such as law enforcement, if we are legally required to do so or if we need to protect our rights or the rights of third parties; and
• Our subsidiaries and affiliates; or a subsequent owner, co-owner or operator of our services and their advisors in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our stock and/or assets, or in connection with bankruptcy proceedings, or other corporate reorganization.

  For a list of these third parties, and a link to their privacy policies, please see below:

• Adsquare
• Carto
• GeoUniq
• Pitney Bowes
• Screen Moguls
• SITO Mobile
• Tapad
• Tiendeo
• Unacast
• Gathr Lab

6. How Long Does GLI Keep The Data

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.

7. Personal Data Transferred from the EU or Switzerland to the United States

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.

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.

8. Your California Privacy Rights

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

9. Changes to This Statement

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.