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Refinition respects the privacy of users, subscribers, publishers or members who visit our site or use our Services (as defined below, collectively or individually, “users”). Our privacy policy explains how Refinition collects, uses, and discloses information through our services, as well as our corporate website. Refinition offers a variety of location, point of interest data and services to its partners, some of which are analytical or geographic, while others involve the use of data from end users and their devices. The Privacy Policy relates only to those services that involve end user or device data. The Refinition services that include end user data are referred to as the “Services” and the website that this privacy policy is on is the “Site.” This policy does not apply to companies that Refinition does not own or control or to people that Refinition does not employ or manage.

Refinition complies with 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. Refinition complies to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.

Services

This privacy policy relates to the Services above, meaning those Refinition services that do make use of end user data. Refinition provides Services that help application developers, publishers, advertisers, marketers and other companies/organizations to learn about their users and customers, based on de-identified and anonymous geolocation data. Our data helps advertisers and marketers to market in more relevant ways to consumers, including their own customers. To provide these Services, we may for instance create anonymous data sets from location data derived from unique devices and the individuals that use them (“Users”). We may then use this data in aggregated, de-identified and anonymous ways, to help marketers improve or better target their ads to Users. Similarly, this data helps applications and services learn more about their Users and helps our customers to tie their likely (anonymous and/or aggregated) audiences to those places.

To perform these services, Refinition may partner with other parties such as advertising agencies, brands, media platforms and publishers (such as app developers) and other advertising platforms (our “Partners”). These Partners may help us to enhance our data sets, or to deploy our data in a way that helps customers, such as marketers or app publisher.

User Information Services

When you engage with our Partners (by using their mobile applications or viewing an ad provided by our Partners) we may collect or receive information about you, your location, your device, your online activity or the ad you are viewing. This Information sometimes may (but does not always or necessarily) include the following: a. Geo-location data of mobile device and an identifier, which is typically latitude/longitude. The device ID from the user’s mobile device, the IDFA for iOS devices or Android ID for Android devices and Windows ID for Windows mobile devices. b. User’s age, gender and other information, if the user provided it to us or to a Partner. c. Information about the device, device type, tablet, smartphone, OS, IP address, network provider, browser type, time-stamp, International Mobile Equipment Identify (IMEI) identifier, time zone, and or a variety of other unique identifiers. d. Information about the ads viewed, where the ad is being served and any click or view activity related to the ad (e.g., whether you view or click through it).

Information receive from Partners may be combined with additional anonymous or de-identified information we collect from third party sources. The Information we have or receive may be associated with geographic locations and other information, used to create marketing segments, or combined with other information.

Use of Information

Refinition uses the Information to enhance, provide services, provide analytics, marketing and advertising services. Refinition also uses the Information to improve our Services and our partner’s services to improve features and functionality. Refinition use the information and our partner’s information, to build attributes about users, on an anonymous or de-identified basis. The anonymous user of that device enjoys music, coffee or other consumer goods and that user may receive information, ads or offers for these goods. Refinition provides analytic which provide our partners with information about their own customers or prospective customers, services and advertising or about trends or behaviors among anonymous de-identified individual or aggregate users; an example maybe the types of users generally tend to shop at sporting goods stores.

Disclosed Information

As part of our Services, we may provide Information (including in the form of demographic and interest segments of users) to certain of our Partners. Their use of the Information is not covered by this privacy policy. For instance, we may share the Information with Publishers, App Developers, and Advertisers. They may use the Information in order to assist web publishers, app developers, and platforms that work with them, to better understand their customer or user base. Refinition may provide similar analytics services to advertisers. We may share the Information with other platforms and service providers –companies that serve ads, provide insights, or provide other marketing services to advertisers and marketers. Some of these Partners may use cookies or web pixels in order to send you targeted ads, engage users, or otherwise locate you. Refinition does not use cookies or pixels. Refinition 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. Further disclosures may be necessary to protect ourselves, our Partners, or any other person or third party, or to enforce legal rights.

Opt Out

We may use Information to enable advertising that is tailored to users’ potential interests, preferences or locations, 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. You also are able to opt out of mobile app interest-based advertising through your mobile device settings. Many of these partners provide their own opt-out mechanisms, available at the Network Advertising Initiative, or NAI’s opt-out page.

Refinition Website

Information and PII Collected on our Site. We may also collect Information, including personal information that you submit to us (“PII”) through our websites. 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, 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. 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 Refinition in improving the Site or Services and creating new services features.

Data Security

Refinition 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 Refinition, and you do so at your own risk. 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.

Children’s Privacy

You should not create a Refinition 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 Refinition to have that child’s information deleted

International Visitors

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 Refinition and its affiliates for any of the purposes described herein. 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.

Additional Information

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 offers a publicly accessible blog and/or some forums. You should be aware that any information you provide in any such areas may be read, collected, and used by others who access them. Our Site may include social media features, such as the Facebook Like button. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing it. 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 Refinition, 600 Congress Ave. 14th floor. Austin, TX 78701. In your request, please specify that you want a “California Privacy Rights Notice.” Please allow at least sixty days for a response. Refinition Contact Information: getrefined@refinition.com

Changes to Privacy Policy: This Privacy Policy may be revised periodically without further notice to you.

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