EFFECTIVE:17 July 2019
TruFactor, a data management platform which provides alternative 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 (“Alternative Data as a Service”).
2. OUR SERVICES
TruFactor may obtain your data from various sources such as telecom provider partners, data partners/vendors, customers, application developers (“Sources”) who may collect your data when you interact with each of them and ingest, curate and manage such user data with our secure, scalable, cloud-based data platform to provide Alternative Data as a Service. TruFactor may also obtain your data from InMobi or its Affiliates.
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. Therefore, using its platform, TruFactor transforms user data into actionable intelligence to enhance customer experience and unlock new revenue streams.
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?
3.1 Information about your device
TruFactor may collect/obtain some or all of the following information about your device: device type (e.g. smartphone, tablet, etc.), operating system (e.g. iOS, Android, Windows, Blackberry), network provider/feeds, 3G or 4G mobile behaviour, mobile browser used, IP address, identifier for application, application version, iOS Identifier for Advertising, iOS Identifier for vendors, Advertising ID, model, manufacture of device, OS version of device, session start/stop time, time zone, subscriber information, network status such as WiFi, the geo-location of your device (using GPS or other geo-location data), location trilateration, etc. 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 software development kit, TruFactor ensures that it infers location only if the application providing such data sets have user’s consent. For data sets obtained from third party Source, 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).
3.2 Demographic data, 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.
To the extent any such information may be considered to be personal information, we ensure compliance 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 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?
(a) InMobi 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.
(b) We may also share your information with InMobi Affiliates so that we can improve our Services and otherwise serve you and our customers better with our offerings.
(c) Sharing Information with third parties such as advisors and law enforcement authorities.
From time to time, we may also need to disclose your information to other third parties, such as law enforcement authorities or our legal advisers, where it is necessary to: comply with the law or regulations; enforce or apply our user terms and conditions; protect our rights, or; preserve the safety of our users.
TruFactor may also share your information in connection with any merger, a sale of assets, due diligence or a financing or acquisition of all or a portion of our business to another company.
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 FOR?
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.
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.
For opting out of interest based advertising services by InMobi, please visit this link: https://www.inmobi.com/page/opt-out/
You may also reach out to firstname.lastname@example.org 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
InMobi (and TruFactor) complies with the Children’s Online Privacy Protection Act (COPPA) in the U.S. and does not knowingly collect personal information about users of sites or applications directed to children under the age of thirteen (13) in the U.S. or any other applicable age in a jurisdiction with age gating privacy requirements for children and does not knowingly behaviorally target such users.
10. OTHER WEBSITES
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.
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.
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 12 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 12 and/or for engaging with you as a business partner, unless otherwise required by law.