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Last Modified: June 2022

Refinition (“we” or “us”) respects your privacy. This Privacy Policy explains how Refinition uses and discloses the personal information it collects or otherwise obtains about you as: (i) a visitor to this website (refinition.com) and/or any other website where this Privacy Policy is posted or linked (collectively, this “Website”); or (ii) a consumer about whom we collect or receive personal information in connection with the performance of our Services (herein referred to as a “User”). This Privacy Policy also provides information about your choices and rights with respect to your personal information.

California Notice at Collection: Refinition collects the categories of personal information listed in the “Categories of personal information collected” subsection of the “California Privacy Rights” section below. As further described in the “Use of Personal Information” section below, we collect this information in order to best serve you and conduct our business. To learn more, please scroll down to the “California Privacy Rights” section.

Our Services

Refinition provides services that help application developers, publishers, advertisers, marketers, and other companies/organizations to learn about their users and customers, based on anonymized geolocation data (herein referred to as our “Services”). Our data helps advertisers and marketers to market in more relevant ways to consumers, including their own customers. To provide our Services, we may, for instance, create data sets from location data derived from Users’ devices and anonymize them prior to use. We may then use these data sets to help marketers improve or better target their ads to Users. Similarly, these data sets 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 our Services, we may partner with other parties, such as advertising agencies, brands, media platforms, publishers (such as app developers), and other advertising platforms (collectively, our “Partners”). These Partners may help us to enhance our data sets or to deploy our data in a way that helps our customers, such as marketers or app publishers.

Collection of Personal Information

We may collect or obtain information relating to you in a variety of ways. Such information may include personal information (i.e., information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Additional details about our collection of personal information can be found below.

Personal information collected through this Website

When you visit and interact with this Website, we may collect the categories of personal information described below.

  • Information you provide: We will collect personal information you provide to us (e.g., your name, email address, telephone number, etc.) when you submit questions, request information, or give us feedback via this Website. Additionally, if this Website includes a publicly accessible blog and/or other forums, we will collect any information you post or otherwise disclose in any such areas. Such information may also be read, collected, and used by others who access this Website.
  • Information collected by automated means: When you visit and interact with this Website, we collect certain information automatically about your browser, device, and/or activity. This information may include your device’s Internet Protocol (“IP”) address, browser type, browser settings, language settings, date(s) and time(s) of your visit(s) to this Website, the webpage that you visited immediately prior to visiting this Website, and information collected through cookies and other similar technologies (as described in the “Cookies and Other Similar Technologies” section below). Additionally, if you access this Website using a mobile device, we may collect information from your device (e.g., GPS and other sensor data) that helps to determine your device’s location.

Personal information collected in connection with our Services

When you engage with our Partners’ digital content (e.g., by using their mobile applications or viewing an ad provided by one of our Partners), we may collect or receive from our Partners information about you (as a User). This information may include the following: (i) information about your browser and device, including your device type, operating system, browser type, browser settings, IP address, mobile device’s geolocation data (typically latitude/longitude coordinates), and mobile device ID (the IDFA for iOS devices and GAID/AAID for Android devices); (ii) your age, gender, and other information, if you provide it to us or to one of our Partners; and (iii) information about the ad you viewed, including where the ad was served and how you engaged with the ad (e.g., whether you viewed or clicked on it).

We generally do not seek personal information that may be considered “sensitive” (e.g., government-issued identification numbers as well as information related to an individual’s racial or ethnic origin, political opinions, religious or other beliefs, health conditions, criminal background, or sexual orientation/sex life), and we ask that individuals not provide such information on or through this Website.

We may combine personal information that we collect (as described above) with information from other sources, and we will use the combined information only for the purposes described in this Privacy Policy.

Cookies and Other Similar Technologies

We (and our service providers and partners) may use cookies (i.e., small text files placed on your device when you visit a website) and other similar technologies (e.g., pixel tags, web beacons, etc.) for various purposes, including to collect information about you.

In particular, cookies may be used on this Website to:

  • distinguish between visitors;
  • help you navigate this Website;
  • enable and improve certain features and functionality;
  • analyze how this Website is used; and
  • provide you with an online experience customized to your needs and preferences.

Most internet browsers are set to automatically accept cookies. However, if you do not want information to be collected from your device via cookies, most browsers have a setting that allows you to decline the use of cookies. Please note that some features of this Website may not work properly if you decline the use of cookies. To learn more about cookies, please visit https://www.allaboutcookies.org.

Google Analytics: We use Google Analytics, a web analytics tool that may set cookies in your web browser, in order to help us understand how users engage with this Website. To learn more about Google Analytics’ data practices, please visit https://support.google.com/analytics/topic/2919631?hl=en&ref_topic=1008008. For opt-out options specific to Google Analytics, please visit https://tools.google.com/dlpage/gaoptout.

Use of Personal Information

We use your personal information for the purpose(s) for which it was collected or provided to us. The specific business purposes for which we use the personal information we collect or otherwise obtain about you are described below.

  • Provide and manage this Website and our Services: We use your personal information in connection with the provision, administration, and management of this Website and our Services.
  • Communicate with you: We use your personal information to respond to your inquiries and fulfill your requests. From time to time, we may use your personal information to send important updates about this Website and communications about changes to this Privacy Policy and/or other applicable terms, conditions, and policies. We may also use your personal information to send you marketing communications and materials (e.g., newsletters).
  • Customize or personalize this Website: We may use your personal information to help us understand which parts of this Website are of most interest to you and customize or personalize your user experience.
  • Identify usage trends and improve this Website: We use your personal information to conduct research and analytics about your use of this Website and identify usage trends. We also use your personal information to identify issues with and improve this Website.
  • Fraud prevention and security monitoring: We use your personal information to detect, prevent, and investigate possible fraud and for other security purposes.
  • Comply with law: We use your personal information to comply with applicable law and/or respond to requests and communications from law enforcement authorities or other government officials.
  • As otherwise necessary or appropriate: We may use your personal information as we believe necessary or appropriate to protect our rights, privacy, safety, or property and/or those of you or others.

Legal basis for use of personal information: Applicable law in your country of residence may require us to set out the legal basis upon which we rely in order to use, retain, and disclose your personal information. Generally, we will use, retain, and disclose your personal information in the following circumstances:

  • we need to perform the contract we have entered into with you or are about to enter into with you;
  • you have consented to such use, retention, and/or disclosure;
  • we have a legitimate interest in using, retaining, and/or disclosing your personal information (e.g., for network and information systems security; data analytics; enhancing, modifying, or improving our services; identifying usage trends, etc.), provided that our interest is not overridden by your interests or fundamental rights and freedoms; or
  • we need to comply with a legal or regulatory obligation to which we are subject. 

Disclosure of Personal Information

In connection with one or more of the purposes outlined in the “Use of Personal Information” section above, we may disclose your personal information to the categories of third parties described below.

  • Our affiliates: We will disclose your personal information to our affiliates as necessary or appropriate.
  • Our service providers: We disclose your personal information to parties that provide services to us, including system/data hosting, management, and support services; data analysis services; and other services related to the operation of this Website and performance of our Services. Our service providers are subject to binding contractual obligations and restrictions on the use of the information we disclose to them for any purpose other than carrying out the services that they are performing of us.
  • Our Partners: As part of our Services, we may disclose certain personal information (including in the form of demographic and interest segments of users) to some of our Partners, such as publishers, app developers, advertisers, and social media platforms. They may use the disclosed personal information in order to better understand their customer or user bases and deliver interest-based ads.
  • Relevant third parties as part of a corporate transaction: In the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with a bankruptcy or similar proceeding), we may disclose or transfer your personal information to certain third parties, such as the acquiring entity and its advisors.
  • Competent governmental and public authorities: We may disclose your personal information to government and law enforcement authorities, in each case to comply with legal or regulatory obligations or requests.
  • Other third parties: We may disclose your personal information to other third parties when directed or with your consent. Additionally, we will disclose your personal information as necessary or appropriate to: (a) comply with applicable law; (b) enforce our terms and conditions; (c) protect our operations; (d) protect our rights, privacy, safety, or property, and/or those of you or others; and (e) allow us to pursue available remedies or limit the damages that we may sustain.

Your Choices and Rights

Our Services may result in you receiving advertising that is tailored to your potential interests, preferences, or location. If you would prefer not to have ads tailored to you in this way, you may opt out of our collection and use of your personal information in connection with our Services by sending an email to [email protected].

You may also be able to opt out of the use of your personal information for interest-based advertising on your browser using the opt-out tools and consumer choice mechanisms provided by interest-based advertising self-regulatory groups by following the links below:

DAA: https://optout.aboutads.info/?c=2&lang=EN

NAI: https://optout.networkadvertising.org/?c=1

Additionally, you may be able to control the collection and use of your personal information for interest-based advertising on your mobile device via your device settings.

Opt out of marketing communications: You can opt out of receiving marketing-related communications from us by following the “unsubscribe” instructions that come with each message from us or contacting us via email at [email protected] or by phone at (877) 673-3463 ext. 3. Please note that even if you opt out of receiving marketing-related communications from us, we may still send you administrative and transactional messages from which you cannot opt out.

Depending on your country (or U.S. state) of residence, you may have a number of rights in relation to your personal information, including the right to:

  • request access to, or a copy of, your personal information, together with details about our handling of your personal information;
  • request that we update the personal information we hold about you or correct such information that is inaccurate or incomplete;
  • restrict the way in which we use your personal information (e.g., if we have no legal right to keep using it) or limit our use of your personal information (e.g., if your personal information is inaccurate or unlawfully held);
  • object to our use of your personal information;
  • withdraw the consent that you have given us to use your personal information, where applicable;
  • request that we delete the personal information we hold about you, subject to certain exceptions prescribed by law;
  • receive the personal information you have provided in a structured, commonly used, and machine-readable format and request the transfer of such information to another entity, to the extent applicable; and
  • lodge a complaint with the appropriate authority in your place of residence regarding our handling of your personal information.

If you are interested in exercising one or more of the rights outlined above, you can contact us at [email protected] or by phone at (877) 673-3463 ext. 3. In order to protect your privacy, we may require proof of your identity before we can act on your request. Where applicable, we will use the requested information for verification purposes only.

California Privacy Rights

The California Consumer Privacy Act (“CCPA”) provides California residents with certain rights. Pursuant to the CCPA, we are providing the following additional details regarding the categories of personal information about California residents that we collect, use, and disclose.

Categories of personal information collected

We have collected the following categories of personal information from California residents within the last twelve (12) months:

  • Identifiers, such as name, IP address, email address, or another similar identifier.
  • Internet or other electronic network activity information, including information about interactions on this Website.
  • Geolocation data, such as device location and IP location.
  • Professional or employment-related information, such as employer name.
  • Inferences, which refers to inferences drawn from any of the information in the categories listed above.

Categories of sources of personal information

As described in the “Collection of Personal Information” section, we collect the above-listed categories of personal information directly from individuals, through automated means, and from third parties.

Disclosures of personal information

 In the preceding twelve (12) months, we have disclosed personal information about California residents in the following categories to service providers:

  • Identifiers
  • Internet or other electronic network activity information
  • Geolocation data
  • Professional or employment-related information
  • Inferences

Sales of personal information 

In the last 12 months, we have sold personal information about California residents in the following categories:

  • Identifiers
  • Geolocation data
  • Inferences

We sell personal information about California residents to the following categories of third parties: 

  • Marketing and advertising partners

Individuals rights and requests

 If you are a California resident, you have the right to request that we:

  • disclose to you the following information covering the 12 months preceding your request:
    • the categories of personal information we collected about you and the categories of sources from which we collected such information;
    • the specific pieces of personal information we collected about you;
    • the business or commercial purpose for collecting personal information about you;
    • the categories of third parties with whom we shared or to whom we disclosed such personal information; and
    • if we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
      • sales, identifying the personal information categories that each category of recipient received; and
      • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
  • delete the personal information we collected from you.

We will not discriminate against you if you decide to exercise your rights under the CCPA.

If you are interested in exercising one or more of the rights outlined above, you can contact us at [email protected] or by phone at (877) 673-3463 ext. 3.

If you authorize a natural person or business entity to submit a request on your behalf (an “Authorized Agent”), the Authorized Agent may use the submission method noted above. As part of our verification process, we will require proof concerning their status as an Authorized Agent, which may include proof of their registration with the California Secretary of State to conduct business in California and/or proof that they have power of attorney in accordance with California probate law. We may also require you to verify your identity directly with us or directly confirm with us that you provided the agent with permission to submit the request.

Personal information “sales” opt-out right

Under the CCPA, some of the personal information disclosures described above may be considered a “sale.” If you are a California resident who is 16 years of age or older, you have the right to direct us to not “sell” your personal information at any time. To exercise your right to opt out, you may submit a request to us by visiting the following link CCPA Opt-Out  or sending an email to [email protected]  with the subject line “Do not sell my personal information.” Upon receipt of your request, we will endeavor to verify and honor it based on the information that we collect and maintain in an identifiable form.

As Authorized Agent may also use the methods described above to submit a request to opt out on your behalf if you provide the agent with the signed permission to do so.

Information 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 will not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

Children’s Privacy

Refinition understands the importance of protecting the privacy of children. This Website is not designed for or intentionally directed to children under the age of 13, and we do not knowingly collect personal information from children under the age of 13. If we become aware that we have received personal information from an individual under the age of 13, we will take reasonable steps to delete such information from our records.

Information Retention

We will retain your personal information only as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or allowed under law.

International Transfers of Personal Information

As a business based in the United States, our collection and use of your personal information may result in the transfer of such information outside of your country of residence.

In order to ensure that your personal information is adequately protected, we transfer your personal information subject to suitable safeguards being in place. For example, if you are based in the European Economic Area (“EEA”), Switzerland, or the United Kingdom (“UK”), we use contracts approved by the European Commission or the UK government that provide appropriate safeguards for personal information that is transferred to countries that have not been recognized by the European Commission or the UK government as providing an adequate level of protection for personal information.

By accessing this Website and providing us with your personal information, you are acknowledging that your personal information may be transferred outside of your country of residence. To find out more about how we safeguard your personal information when it is transferred across borders, please contact us using the details provided in the “Contact Us” section below.

Third-Party Websites

This Website may include links to other websites whose privacy practices may differ from ours. This Privacy Policy does not address, and we are not responsible for, the information handling or privacy practices of any third parties. Information collected from you by those companies is governed by their privacy policies or statements. The inclusion of a link on this Website does not imply that we endorse the practices of the linked website.

This Website may include social media features, such as the Facebook “Like” button. These features may collect your device’s IP address and details about the page you are visiting on this Website 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 this Website. Your interactions with any of these features are governed by the privacy policy of the company providing them.

Updates to this Privacy Policy

We may update or amend this Privacy Policy from time to time to reflect changes in our practices with respect to the collection, use, and disclosure of personal information and/or changes in applicable law. The “Last Modified” date at the top of this page indicates when this Privacy Policy was last revised. Any changes will become effective when we post a revised version of this Privacy Policy on this Website. We encourage you to review this Privacy Policy periodically to remain informed about our information handling and privacy practices.

Contact Us

If you have any questions or concerns about this Privacy Policy or our practices, please contact us at [email protected] or by phone at (877) 673-3463.

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