Privacy Policy

LAST UPDATED:  NOVEMBER 2019


EFFECTIVE: JANUARY 2020


1. INTRODUCTION


TruFactor, a data management platform which provides data as a service aims to enable telecom providers, market analysts, marketers and/or organizations representing various industries (“Customers”) to transform their digital assets into strategic knowledge and provide a competitive advantage in a world of connected devices (“Data as a Service”).


This Privacy Policy explains how TruFactor (“TruFactor” or “we”, “us”, “our”, a business unit of InMobi Pte. Ltd, (“InMobi”) its subsidiaries and affiliated companies (“Affiliates”) collects, obtains, uses, secures, and/or discloses end users’ (“you” or “your”) information in the course of its Data as a Service offering (“Services”). TruFactor is committed to respecting and protecting individuals’ privacy rights.


The scope of this Privacy Policy excludes data practices related to any advertising specific services/channels, mobile applications or software feature owned or operated by InMobi or its Affiliates.  Please review the privacy policies made available for those respective services or offerings.


2. OUR SERVICES


TruFactor may obtain information about you from various sources such as telecom provider partners, data partners/vendors, customers, and/or application developers (“Sources”) who may collect information about you when you interact with each of them. TruFactor may also obtain data about you from InMobi or its Affiliates.  We use this information to provide Data as a Service.


As a platform provider, TruFactor is not responsible for a Sources’ collection of or independent use of your data, so we urge you to refer the privacy policies of the respective Sources that you interact with.


TruFactor’s processing of your data is in accordance with the applicable contract terms where the data is obtained from third parties, applicable privacy laws and directives and the terms of this Policy.


3. WHAT INFORMATION DO WE COLLECT/OBTAIN?


Information about your device. TruFactor may collect/obtain some or all of the following information about your device from Sources and/or its Affiliates:

     
  • (a) Device identifiers. Device identifiers are alphanumeric strings that are unique to your device. These include:
             
    • • iOS devices’ Identifier for Advertising (IDFA) and iOS Identifier for vendors
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    • • Google Advertising ID (GAID), or Android ID for Android devices
    •      
  • (b) Location information where permitted, including:

             
    • • Geo-location or precise location of your device
    •        
    • • Location information we infer based on data collected through a WiFi identifier that your device is connected to, in accordance with applicable law and provided location access is permitted
    •        
    • • Location information we infer from your device’s IP address
    •        
    • • Location trilateration
    •      
  • (c) Network information, including

             
    • • Mobile carrier
    •        
    • • Network provider or ISP (3G, 4G, 5G)
    •        
    • • Network type (e.g., WiFi or cellular) and status
    •        
    • • IP address
    •        
    • • Session start/ stop time
    •      
  • (d) Information about the app or site and our Software Development Kit (SDK), including:

             
    • • App or site name or version
    •        
    • • App identifier
    •        
    • • SDK version
    •        
    • • API key identifier
    •      
  • (e) Other information about your device, including:

             
    • • Device type (e.g., smart phone/ tablet)
    •        
    • • Operating system (e.g., iOS, Android, Windows, Blackberry)
    •        
    • • Mobile browser used (e.g., Chrome, Safari, Firefox)
    •        
    • • Language settings and time zone
    •      
  • (f) Demographic Data, including:

             
    • • subscription data including total phone bill amounts,
    •        
    • • data usage
    •        
    • • total number of calls/texts
    •        
    • • and/or information about your interaction with various products/services of Sources or Customers
    •      

In some countries, some of these data sets may be considered to be personal information, in which case, we ensure compliance with applicable laws in our use of the same, to the extent applicable in such jurisdictions.


TruFactor does not directly interact with end users. To the extent, any wifi identifier information is obtained through InMobi or its Affiliate’s owned and operated applications or SDK, TruFactor infers location only if the application providing such data sets have user’s consent. For data sets obtained from third party Sources, the responsibility to obtain consent remains with the Sources and TruFactor may only infer the geo location of a device based on data collected through a wifi identifier(s) that the device is connected to, subject to country specific laws and/or industry guidelines related to such collection or inference practices (e.g. pursuant to confirmation of consent from Sources).


To the extent any such information may be considered to be personal information, we comply with applicable laws in our collection or use of the same, to the extent applicable or required in such jurisdictions including certain data subject rights that you may enjoy and implement reasonable technical measures to ensure prevention of unauthorised disclosure of such personal information in our custody.


4. HOW DO WE USE YOUR INFORMATION?


TruFactor may create segments, reports, profiles, audiences, insights, conduct statistical analytics etc. (“Data Derivatives”) from the user data it obtains from Sources to cater to Customers from various industries in understanding market trends and/or user behaviour etc. 


TruFactor uses your information as described above in this Policy and in accordance with your election regarding the use of your information as you may provide to the Sources. It may sell, license and/or otherwise transfer Data Derivatives on an aggregated and/or anonymized format to its Customers in performing its Services. Our Customers and InMobi or its Affiliates may also use Data Derivatives for serving interest-based advertising.


5. WHO DO WE SHARE INFORMATION WITH?

     
  • • Customers. TruFactor may share Data Derivatives with our Customer as part of Services. Any Customer’s use of the information we share with them will be governed by their privacy policies;
  •  
  • • Affiliates. We may share personal or non-personal information with Affiliates so that the services of InMobi and/or its Affiliates may be improved and otherwise to serve you and/or our customers better with all our offerings;
  •  
  • • Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity; and
  •  
  • • Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.


6. HOW DO WE KEEP INFORMATION SECURE?


TruFactor uses reasonable technical and organizational measures to protect the information it collects/obtains about you in compliance with its legal and privacy requirements and contractual obligations. We also seek appropriate contractual protection from our partners regarding their collection, use or treatment of user data.


7. HOW LONG DO WE KEEP INFORMATION?


TruFactor may retain your information for a period of up to thirteen (13) months, unless otherwise required by law or applicable data retention period stated in a contract. Any aggregated and/or anonymized Data Derivatives may be retained for a longer period of up to twenty five (25) months towards its business purposes.


TruFactor may retain the information it obtains about you as per the instructions of its Sources who provide such information or as required to fulfil our contractual obligations.


After the applicable retention period, TruFactor may retain and use user data in an aggregated format, as necessary for internal analytical purposes, to comply with its legal obligations, resolve disputes and enforce agreements. Please note that the use cases stated in this provision will apply as an exception to your data subject or consumer rights related requests.


8. OPTING OUT


TruFactor does not directly interact with end users and therefore, does not collect your information directly. We urge you to refer the privacy policies of the respective Sources that you may interact with, to exercise your opt-out options. For InMobi or its Affiliate’s owned and operated applications, you may exercise opt-out options as set out in the links below.


http://1weatherapp.com/privacy


http://tweetcaster.com/privacy/


http://baconreader.com/privacy/


https://www.inmobi.com/glance/privacy-policy/


For opting out of interest based advertising services by InMobi, please visit this link: https://www.inmobi.com/page/opt-out/ 

 

California Residents: Additional rights for residents of the State of California (in the United States) effective the later of (i) January 1, 2020 or (ii) the date on which CCPA comes in effect:

     
  • • You have a right to exercise certain consumer rights such as request to know/ disclose/ access/ delete your data, collected in the last 12 months, by writing to us at privacy@inmobi.com.
  •  
  • • You have the right to opt out of selling of your data by clicking on the following link: - Do not sell my data.


You may also reach out to privacy@inmobi.com for any further assistance in this regard. Where device identifiers or subscriber id or advertising identifiers or such similar identifiers are not available with us in a raw format, we may not be in a position to address your request.


9. PRIVACY OF CHILDREN


TruFactor complies with the age-gating requirements under applicable privacy laws such as Children’s Online Privacy Protection Act (COPPA) and California Consumer Privacy Act (CCPA) in the U.S. and GDPR in EEA and does not knowingly behaviorally target such users.


10. OTHER WEBSITES


Our website may contain links to other websites. You should be aware that we are not responsible for the privacy practices of such other websites as those may have different privacy policies and terms of use and are not associated with us. You agree that we cannot control these links and we shall not be responsible for any use of such websites.


11. CHANGES TO THIS PRIVACY POLICY


We may amend this Privacy Policy at any time. The amended Privacy Policy will be displayed on our site. If we make any material changes, we will notify you by means of a notice on this site prior to the change becoming effective. Please check our Privacy Policy regularly to ensure you have read the latest version.


12. YOUR INTERACTION WITH TRUFACTOR WEBSITE


12.1 WHAT INFORMATION DO WE COLLECT?
If you choose to create an account on the TruFactor website we may collect your username, password, email address, country, and preferred account type when you register. We wish to clarify that, in this context, your information may be used by TruFactor to contact you for the only purpose of engaging with TruFactor or InMobi or Affiliates as a business partner. This data is not shared by TruFactor with any third parties.


If you provide your name or email address, we may use that information to send invitation to you to visit or register with our site or become a business partner with us. Please do not share any personal or sensitive information with us if you do not have the right to share the same or if you are not interested in conducted business with us. Kindly note that this Section 13 is solely intended for business communications. We may use information about how you leave our site (e.g. which website you visit immediately after visiting our site). We may use cookies to help us collect and store this information.


12.2 HOW DO WE USE THE INFORMATION WE COLLECT?
We use the account information and other information you provide to manage your account, communicate with you, conduct business with you (e.g. reporting and payment), personalise our website, comply with your requests, and inform you about products and services in accordance with your marketing preferences for business purposes. We use your usage information to analyse our web traffic, to figure out how often customers use parts of the site, to improve the site and generally to make it appealing to as many users as possible.


From time to time, we may need to disclose your information to third parties such as to law enforcement authorities or our legal advisers, where it is necessary to comply with the law or regulation; enforce or apply our user terms and conditions; to protect our rights, or to preserve the safety of our users.


We may also share your personal information with companies that provide services to help us with our business activities (e.g. processing payments or submitting emails to you on our behalf), in connection with any merger, a sale of assets, or a financing or acquisition of all or a portion of our business to another company. Whenever we share your personal information for this reason, we will ensure that the recipient is bound by all appropriate confidentiality obligations and that it is committed to using your personal information only for the purposes for which you originally provided it.


You should also be aware that the information submitted to public areas, such as our blogs, may be read, collected, and used by others who access them.


If you interact with social media features on our site, such as the Facebook Like button, or use your social network credentials to comment on our blog, these features may collect information about your use of this site as well as post information about your activities on this site to your profile page. Your interactions with these features are governed by the privacy policy of the company providing it.


12.3 HOW DO WE KEEP INFORMATION SECURE?
We use appropriate technical and organizational security measures to protect the information we collect. We use multiple electronic, procedural, and physical security measures to protect against unauthorized or unlawful use or alteration of information, and against any accidental loss, destruction, or damage to information. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure.


12.4 HOW LONG DO YOU KEEP INFORMATION?
Considering this Section 13 is intended for business communications and marketing only, we retain information for as long as it is necessary to fulfil the purposes outlined in this Section 13 and/or for engaging with you as a business partner, unless otherwise required by law.


13. CONTACTING US


If you have any questions about this Privacy Policy, please contact us at privacy@inmobi.com.