TRUSTe’s Web Privacy and TRUSTed Data program requirements including transparency, accountability and choice regarding the collection and use of your information. The TRUSTe programs cover only information that is received through Factual’s website and Factual’s third party partners for its data enrichment services.
Factual complies with the U.S. – E.U. Safe Harbor framework and the U.S. - Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. Factual has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Factual’s certification, please visit http://www.export.gov/safeharbor/.
To perform our Services, we may partner with other parties such as brands, advertising agencies, media platforms and publishers (such as app developers) and other advertising platforms (our “Partners”). These Partners may help us to enhance our datasets, or to deploy our data in a way that helps customers, such as marketers or app developers.
When you engage with our Partners (e.g., by using their mobile applications or viewing an ad provided by our Partners) we may collect or receive information (collectively, “Information”) about you, your location, your device, your online activity or the ad you are viewing. This Information sometimes may (but does not necessarily) include the following:
the geolocation data of your mobile device and an identifier, which may be expressed by precise latitude/longitude and/or at a GPS-level. The identifier may be a device ID from the user’s mobile device, such as the IDFA for iOS devices or Android ID for Android devices.
a User’s age, gender, date of birth and other information, if the User provided it to us or to a Partner.
other information about your device, such as: device type (e.g., tablet, smartphone), operating system, IP address, network provider, browser type (e.g., Firefox, Chrome, Safari), SDKs running on your device, time-stamp, International Mobile Equipment Identify (IMEI) identifier, time zone, or other unique device identifiers;
Information about the ad you have viewed, such as: what ad you have viewed, and what type or category of content the ad includes, where the ad is being served (e.g., what website or app), and any click or view activity related to the ad (e.g., whether you view or click through it).
The Information that we receive from our Partners may be combined with additional anonymous or de-identified information we collect or receive from 3rd party sources. The Information we have or receive (such as unique and device identifiers) may be associated with geographic locations (based, for instance, on latitude/longitude) and other information (e.g., census data), used to create interest-based segments, or combined with other demographic, interest-based and business information.
Generally speaking, Factual uses the Information to operate, maintain, enhance, and provide our Services, and sometimes to partner with other platforms and services that provide analytics, marketing and advertising services (i.e., the types of Partners we’ve described above). Factual also uses the Information to understand the usage trends and preferences of our Users and our Partners’ Users, to improve the Services and to create new features and functionality.
We often use the Information (including Information received from our Partners) to help determine demographic and interest attributes about Users, on an anonymous or de-identified basis. We may assign demographic or interest-based segments to a user based on their location(s) and provide this information to our Partners to enable them to provide more relevant content, services and advertising, For instance, if we often see (or if our Information suggests) that a particular device is present at or near music venues, we may infer that the (anonymous) user of that device enjoys music, and that User may receive information, ads or offers about music concerts in a relevant geographic area.
We may also provide analytic tools or information based on our Information, which provide our Partners with information about their own customers or prospective customers, about the performance of their content, services and advertising (for instance, what effect certain ads, as opposed to other ads, have), or about trends or behaviors among anonymous or aggregate Users (for instance, what types of Users generally tend to shop at certain stores).
With Web Publishers, App Developers, and Advertisers. We may share the Information in order to assist web publishers, app developers, and platforms that work with them, to better understand their customer or user base. For instance, we may help an app that serves music to its users understand more about its users’ likely interests, based on aggregate or anonymous user behavior. Or, we may provide similar analytics services to advertisers, based on our Information.
With other Partners and platforms. We may share the Information with other platforms and service providers – for instance, companies that serve ads, provide insights, or provide other marketing services to advertisers and marketers. For instance, we may integrate our Services or partner with platforms that provide web-based advertising or analytics services, to help marketers send more relevant ads to their own customers. Sometimes, we may share the Information so that we or our Partners may reach customers across multiple channels – for instance, to find similar or common users on web and mobile devices, based on common Information or behavior. Sometimes, we may share the Information in order to enhance or verify the accuracy or completeness of it.
Factual may disclose Information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws respond to a court order, judicial or other government subpoena, or warrant in the manner required by the requesting entity. We may also disclose Information if we believe it is necessary to protect ourselves, our Partners, or any other person or third party, or to enforce any legal rights.
In the event that Factual is acquired by or merged with a third-party entity or is potentially going to be acquired by or merged with a third party entity, or if its substantial assets are acquired by a third party, we may transfer or assign the Information that we have collected from Users (or from our own direct customers and account-holders, including our Partners) as part of that actual or potential merger, acquisition, sale, or other change of control.
As we’ve described above, we may use Information to enable advertising that is more tailored to Users’ inferred interests, preferences and locations, and to help companies and marketers learn more about their actual or intended audiences. If you prefer not to have ads tailored to you in this way, you may opt out of those Services, including our creation of demographic information and interest segments used to target those ads, by clicking here. Please note that if you opt out in this way, you may still receive non-tailored (generally, less relevant) ads that are not based on your inferred interests.
You also may opt out of mobile app interest-based advertising through your mobile device settings, as described below, and as applicable to most (but not necessarily all) mobile devices. When we receive a signal that you have done so, we will honor that signal and no longer use information collected through your mobile apps to deliver interest-based advertising to your device.
Please note: We provide the below information purely for reference, and do not guarantee that is accurate or up-to-date as to the device that you are using: you should review the current, applicable device settings and other information provided by Apple and Google respectively, for the most current and accurate information about how device settings operate and how they permit ad targeting and data collection to be limited.
Opting Out on iOS Devices Such as iPhones, iPads or iPods
If you have an Apple device, you can opt out of Factual’s app-based tracking for interest-based advertising by updating to iOS 6.0 or higher, and setting Limit Ad Tracking to ‘ON’. You can do this by clicking on Settings -> General -> About -> Advertising and toggling Limit Ad Tracking to ‘ON’. Our systems are designed to respect your choice and not use information to provide interest-based advertising based on data collected automatically from apps when this setting is ON.
Opting Out on Android Devices
If you have an Android device, you can opt out of Factual’s app-based tracking for interest-based advertising by taking the following steps:
Open the Google Settings app on your device
Opt out of interest-based ads
Our systems are likewise designed to respect these choices transmitted by your Android device.
In addition to the above mobile-based choices, we sometimes work with web-based partners, such as to coordinate and integrate information across platforms. Many of these partners provide their own opt-out mechanisms, available at the Network Advertising Initiative, or NAI’s opt-out page. You can opt out of additional targeted advertising services by visiting the Digital Advertising Alliance’s opt-out page, at http://www.aboutads.info.
Information and PII Collected on our Site.
Our server logs also automatically collect information such as your IP address, pages you access, your browser type and language, and the date and time of your visit, which helps us track users’ movements around our site and understand trends.
We may assign your computer one or more cookies which may collect information to facilitate access to our website and to personalize your online experience. We, and third-party service providers with whom we partner, may use standard Internet tools such as cookies and web beacons, which collect information that tracks your use of our website and enables us to customize our services. These cookies and web beacons may be set by our third-party partners and service providers to assist us in managing the content on our Site and in understanding how users interact with our Site. These technologies collect non-personal information about your visit to our Site. Factual does not control the third party technologies employed on its Site for this purpose.
If you have provided us with your email address, we will use your email address, without further consent, for administrative communications such as notifying you of major Site and Services updates, for customer service purposes, to address copyright infringement or defamation issues, to contact you regarding any content that you have posted to or downloaded from the Site or Services, and/or to provide you with additional information and service offers (e.g., our newsletter). If you do not want to receive promotional emails, please notify us, or follow the unsubscribe instructions within the email.
We may disclose user information to affiliated companies or other businesses or persons to: provide web site hosting, maintenance, and security services; fulfill orders; conduct data analysis and create reports; offer certain functionality; and assist Factual in improving the Site or Services and creating new services features.
What are “Cookies,” and “Pixel Tags” and How Do We Use Them?
Cookies are small data files that contain a string of characters, such as an anonymous unique browser identifier. Cookies are stored on your computer or other device and act as anonymous tags that identify your device, but not you personally. Our servers, or those of a Partner we work with, may send your device a cookie when you visit a website, including our Site, or a web page on which their ad or content is shown. A pixel tag (also commonly known as a web beacon or clear GIF) is an invisible 1 x 1 pixel that is placed on certain web pages. When you access these web pages, pixel tags generate a generic notice of the visit and permit us, or our Partners, to set or read our cookies. Pixel tags are used in combination with cookies to anonymously track the activity on a site by a particular device. When you turn off cookies, pixel tags simply detect an anonymous website visit.
Factual uses physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. We cannot, however, ensure or warrant the security of any information you transmit to Factual, and you do so at your own risk. In other words, there is no guarantee that any Information you provide may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
You should not create a Factual account unless you are legally old enough to form a binding contract and in any case are 13 years of age or older. In the unlikely event that you are the parent or legal guardian of a child under 13 who has registered with the Site or Services, then please contact Factual to have that child's information deleted.
For Users visiting the Site or Services from the European Economic Area or other non-U.S. territories, please note that any data you enter into the Site or Services or that we gather as a result of your visit to the Site or use of the Services will be transferred outside the European Economic Area or such other non-U.S. territory for use by Factual and its affiliates for any of the purposes described herein. In addition, because Factual operates globally, we may make information we gather available to worldwide business units and affiliates. By providing using and/or any data on the Site or Services, you hereby expressly consent to such transfers of your data to the United States or other countries.
Our Site and Services may include links to other websites whose privacy practices may differ from ours. Information collected from you by those companies is governed by their privacy policies or statements.
Our Site may offer a publicly accessible blog and/or a support forum. You should be aware that any information you provide in any such areas may be read, collected, and used by others who access them.
California Residents. Under California Civil Code sections 1798.83-1798.84, users who are California residents are entitled to request and receive once a year, free of charge, a notice from us describing what categories of personal customer information we share with third parties for their direct marketing purposes. That notice will identify the categories of information shared, the third parties and affiliates with which it was shared, and their names and addresses. If you are a California resident and would like a copy of this notice, please submit a written request to Factual Inc., P.O. Box 49348, Los Angeles, CA 90049. In your request, please specify that you want a “California Privacy Rights Notice.” Please allow at least thirty days for a response.
Factual Contact Information
Please contact Factual Inc. with any questions or comments about this Privacy Notice, your personal information, and our third-party disclosure practices or your consent choices at: Factual Inc., P.O. Box 49348, Los Angeles, CA 90049 or by email. We will respond to your inquiry within 30 days of its receipt. If you are not satisfied with our response you can contact TRUSTe here.
Effective Date: August 10, 2016
Factual values the privacy of its customers and consumers. Factual’s customers include clients of Factual’s Services (defined below), third parties (e.g., publishers) that provide data to Factual, as well as brands, advertising agencies, application developers, media and technology platforms, and others who visit any Factual website that links to this policy (“Site”) or otherwise use Factual’s Services (collectively “Customers”). “Consumers” include individuals who use Factual’s applications or who use applications from which Factual receives or collects data (such as applications that are owned and/or operated by Factual’s Customers).
When Consumers use Factual applications or engage with our Customers (e.g., by using their mobile applications or viewing an ad provided by our Customers, or by using an app that has integrated our software development kit (“SDK”)), we may collect or receive Device Data that may (but does not necessarily) include the following:
The Device Data that Factual receives from its Customers or from Consumers may be combined with additional information Factual collects or receives from third-party sources. For example, Factual may have information about consumer products, events held at specific locations, street addresses, and categories of geographic locations or points of interest. While such information is associated with a specific device, it is treated as Device Data.
Please see Section 5 below for a description of the information that Factual collects through its Site and in connection with Factual accounts.
Factual generally uses the Device Data it collects or receives for the following purposes:
Factual’s Services help application developers, publishers, advertisers, marketers, and other companies and organizations learn more about Consumers based on Device Data including Device Geolocation Data. For example, the Services help Customers:
Factual may also work with third parties, such as brands, advertising agencies, media platforms and publishers (such as app developers), and other advertising platforms to improve their own services. The above list is not exhaustive, but it is intended to provide illustrative examples of how Factual uses the Device Data it collects and receives. Factual may retain the Device Data:
Factual may retain Device Data beyond these time periods as required by law.
Please see Section 5. below for a description of how Factual may disclose information collected from this Site and/or Factual accounts.
Please note that Consumers who use more than one mobile device should renew their opt-out choices on each device. Consumers who opt out from use of their Device Data as part of Factual’s Services may continue to receive interest-based advertising from other companies.
Consumers who have downloaded Factual’s applications, but who no longer wish to provide information to Factual for interest-based advertising purposes, should opt out through AppChoices as described above.
Factual may permit third parties to collect information on its Site and combine that information with other information collected on non-affiliated websites or applications over time. These third parties may use technologies, including cookies and web beacons, to collect information about Consumers’ or Customers’ use of the Site in order to analyze, report on, or customize content or advertising on the Factual Site or on other sites, or to help us operate and improve the Site. To find out more about interest-based advertising in the web environment, and how to opt-out of information collection for this purpose by companies that participate in the Network Advertising Initiative or the Digital Advertising Alliance, visit NAI’s opt-out page or DAA’s Consumer Choice Page. EEA and Swiss residents, please refer to www.youronlinechoices.com.
Factual sometimes works with web-based Customers, such as to coordinate and integrate information across platforms. To find out more about interest-based advertising in the web environment, and how to opt-out of Web viewing information collection for this purpose by companies that participate in the Network Advertising Initiative or the Digital Advertising Alliance, visit NAI’s opt-out page or DAA’s Consumer Choice Page. EEA and Swiss residents please refer to www.youronlinechoices.com.
For Users who provide Factual with an email address, Factual may use such email addresses for administrative communications such as marketing, notifying Users of major Site and Services updates, for customer service purposes, to address copyright infringement or defamation issues, or to contact Users regarding any content that they have posted to or downloaded from the Site or Services. If you do not want to receive promotional emails, please follow the unsubscribe instructions within the email.
To review or update your contact or billing information maintained by Factual, you can contact us via our contact form.
Factual’s server logs also automatically collect User information such as Users’ IP addresses, pages Users access, browser type and language, and the date and time of visits, which helps Factual track use of the Site and understand trends.
Factual may place one or more cookies on a User’s computer if the User visits the Factual Site. Factual’s cookies may collect information to facilitate access to Factual’s website and to personalize the User’s online experience.
Third-party service providers with whom Factual works, such as Google Analytics, may use tools such as cookies, web beacons, and similar technologies which collect information that tracks Users’ use of the Site (and other unrelated sites over time). These technologies may be used to assist Factual in offering the Site, such as managing the content on the Site and understanding how Users interact with the Site, and for interest-based advertising purposes (including to show Users ads about Factual services on unrelated websites). Factual does not control the third-party technologies employed on its Site for this purpose. To learn more about how Google Analytics collects and processes data and the choices Users may have to control these activities, please visit http://www.google.com/intl/en/policies/privacy/partners. Please see Section 4(b) above to learn about and exercise User choices regarding interest-based advertising by third parties through the Site.
Factual may disclose personal information collected on this Site or through other account tools (including contact or billing information):
Factual uses reasonable physical, managerial, and technical safeguards to preserve the integrity and security of Users’ personal information.
Factual does not knowingly collect personal information from children under 13 years old or from websites or online services directed to children under 13 years old. Users should not create Factual accounts unless they are legally old enough to form a binding contract and in any case are 13 years of age or older. In the unlikely event that you are the parent or legal guardian of a child under 13 who has registered with the Site or Services, please contact Factual to have your child's personal information deleted.
For Users visiting the Site or Consumers whose data is collected through the Services from non-U.S. territories, please note that any data entered into the Site or that is collected through the Services will be transferred outside such non-U.S. territory for use by Factual and its affiliates for any of the purposes described herein. In addition, because Factual operates globally, it may make information it gathers available to worldwide business units and affiliates. By providing and/or using any data on the Site or through Factual’s Services, individuals hereby expressly consent to such transfers of data to the United States or other countries.
More Information for Individuals from the European Economic Area (“EEA”) and Switzerland
What is the legal basis on which Factual relies to process personal data?
On some occasions, Factual may process personal data with the individual’s consent (for example, when a User agrees that Factual may place cookies, or process information that the User inputs into the Factual website).
On other occasions, Factual may process personal data when Factual needs to do this to fulfil a contract (for example, for billing purposes) or where Factual is required to do this by law.
Factual also processes a User’s/Consumer data when it is in Factual's or its Customer's legitimate interests to do this and when these interests are not overridden by the individual’s data protection rights. Those legitimate interests include providing services to enable Factual’s Customers to provide more relevant ads and content.
Who is responsible for the data?
For the majority of the services it offers, Factual, Inc. is a data processor who processes data on behalf of its Customers.
For certain other services for which Factual is a data controller and for processing of personal data derived from the Site, Factual, Inc. is the data controller of the data.
If you have any questions or comments please contact Factual at the contact details set out at Section 11 below. Where Factual is a data controller, Factual’s representative in the EU is Factual EMEA Limited.
You may ask Factual for a copy of your information, to correct it, erase it, and to transfer it to other organisations at your request. You also have rights to object to some processing and, where Factual has asked for your consent to process your data, to withdraw this consent. Factual will only send marketing to you, if you have indicated that you are happy to receive marketing information from us. In addition, you have rights to object to direct marketing at any time. Where Factual processes your data because Factual has a legitimate interest in doing so (as explained above), you also have a right to object to this. These rights may be limited in some situations – for example, where Factual can demonstrate that it has a legal requirement to process your data.
Factual hopes to satisfy queries you may have about the way Factual processes your data. For details on how to opt-out of Factual's interest-based advertising services, please see Section 4(a) above.
However, if you have unresolved concerns you may also have the right to make a complaint to the relevant data protection supervisory authority or to seek a remedy through the courts if you believe that your rights have been breached.
Factual’s Site may include links to other websites, apps, and services whose privacy practices may differ from Factual’s practices. Information collected from by those companies is governed by their privacy policies or statements.
Factual’s Site may offer a publicly accessible blog and/or a support forum. Any information provided in any such areas may be read, collected, and used by others including the general public.