Locately Privacy Notice

Effective Date: December 2012

At Locately, we value our relationship with you and place the highest importance on respecting and protecting your privacy. We foster a culture of Privacy by Design, in which safeguarding your privacy is a foundational component of our business, research, and technology development. We are committed to meeting and exceeding best privacy practices in the industry. We follow CTIA's Best Practices and Guidelines for Location-Based Services which can be downloaded from www.CTIA.org.

What Does Locately Do?

Locately conducts location-based market research to better understand consumer behavior. You can opt-in to participate as a member of a market research panel (a “Locately Panel”). If you do so, we will collect location data from your mobile phone and responses to surveys we send you, and use that information to derive consumer insights, such as how much consumers travel, where they shop, which stores they drive past, and the order in which they visit major retail stores or food locations. We only provide aggregate information to our customers; your personal information will not be disclosed to third parties for their own marketing purposes. This Privacy Notice explains how we collect, use and disclose your personal information as well as the choices you have if you choose to participate in a Locately Panel. To join a Panel, just download our mobile app.

What Personal Information Does Locately Collect?

We collect the following types of information from our panelists:

Contact Information: We collect your email address and (in some cases) your mobile phone number. We use your email address and phone number to send you communications, such as surveys and rewards information. We may collect other contact information, such as your mailing address, if we have to mail a reward to you.

Location Data: If you opt-in to participate by allowing us to collect location data, we will collect real-time GPS and other location information from your mobile device. We only collect this information when your mobile device is set to allow collection of location data.

Mobile Device Data: We may collect information about your mobile device, such as device model, carrier, and basic usage statistics about your device. We may also collect battery life information to optimize location sampling based upon the remaining battery life. In compliance with industry best practices, we do not collect your mobile device’s unique device identifier (UDID).

Survey Data: As a panelist, we will send you surveys regarding your shopping experiences and behavior, and we will combine your survey responses with your location data and demographic data to get a picture of your shopping behavior.

Demographic Data: We may collect general information, such as your age range, income, gender, brand preferences and other demographic data that helps us understand you as a shopper.

Data from Cookies: Our websites and mobile apps use cookies and other data collection technologies (such as web beacons and server logs) to collect information from the device you use to access our websites, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also record your IP address.

We treat all of the information we collect as “Personal Information” if it can be used to locate, identity or contact a particular person. We de-identify and aggregate information from groups of panelists to provide our services to our customers, so that our customers do not receive any Personal Information from us.

How Does Locately Use Personal Information?

We use all the information we collect to derive market research insights, and (on a de-identified basis only) provide consumer behavior analytics and business intelligence to our customers.

We use your Personal Information as needed to manage our relationship with you, including providing customer service and delivering surveys and rewards. We may provide you with marketing communications and offers for products and services from our partners, including for offers targeted based on your interests, shopping behavior and location. We also use your Personal Information for everyday business purposes, such as product development, website/app administration, fraud prevention, and legal compliance.

Does Locately Share Personal Information with Other Companies

We do not share any Personal Information with third parties for their own marketing purposes.

We may share your Personal Information with our affiliates, which only use your Personal Information for the purposes listed above, or with our service providers, who are bound by law or contract to protect your Personal Information and only use your Personal Information in accordance with our instructions. We may also share your Personal Information as needed to effect the sale or transfer of business assets, to enforce our rights, protect our property, or protect the rights, property or safety of others, or as needed support external auditing, compliance and corporate governance functions. We will always disclose Personal Information when required to do so by law, such as in response to a subpoena, including to law enforcement agencies and courts in the United States and other countries where we operate.

Please note that we will disclose information about you that is not personally identifiable. For example, we may publish reports that contain aggregated and statistical data, as well as insights from your behavior and survey responses. These reports do not contain any information that would enable the recipient to contact, locate or identify you.

Does Locately Collect Information from Children?

Individuals must be at least 18 years old to participate in Locately panels. If you believe that we have collected information from a child under 18, please contact us at privacy@locately.com so that we can investigate. We will immediately delete any information associated with minors upon discovery that we have collected this information.

Does Locately Work with Third Party Advertising Companies?

Locately has relationships with third party advertising companies that place advertisements on its website and other websites, and that perform tracking and reporting functions for its website and other websites. These third party advertising companies may place cookies on your computer when you visit our website so that they can display targeted advertisements to you. These third party advertising companies do not collect Personal Information in this process, and we do not give any Personal Information to them. However, this Privacy Notice does not cover the collection methods or use of the information collected by these vendors. You may opt out of being targeted by many third party advertising companies by visiting www.networkadvertising.org/consumer/opt_out.asp.

What Choices Does a Locately Panelist Have?

Most importantly, you can choose whether to become a panelist. We will not collect any Personal Information unless you opt-in to our programs by downloading the app and explicitly agree that we can collect your location data and send you surveys.

You may discontinue participating in the Panel at any time by removing the app from your mobile device. If you do this, we will no longer collect information from your device (or send you surveys), but we will retain your Personal Information in our records. If you wish to have us delete your Personal Information, you can contact us at privacy@locately.com and we will assist you with that request.

If you turn off location-based services on your mobile phone, Locately (and other companies) will not capture any location information.

If you have any questions about privacy or need assistance with accessing or updating any of your Personal Information, you can contact us at privacy@locately.com.

What Security Controls Does Locately Use?

Locately has an information security program with administrative, physical and technical controls designed to protect your Personal Information. All Personal Information is sent to Locately servers over an encrypted data channel and is stored according to industry standard practices for data security and protection. All of our data is stored on secure servers within the USA.

Can Locately Change this Privacy Notice?

From time to time, we may update this Privacy Notice to reflect new or different privacy practices. We will place a notice online when we make material changes to this the Privacy Statement. Additionally, if the changes will materially affect the way we use or disclose previously-collected Personal Information, we will notify you about the change by sending a notice to the email address associated with your account. You will then have an opportunity to discontinue participation in the Locately Panel.

How Can I Contact Locately?

If you have any questions about this Privacy Policy, please contact us at: privacy@locately.com. You can also write to us at:

76 Summer St, 5th Floor
Boston, MA 02110