LOCALSENSOR PLATFORM PRIVACY POLICY

Effective date: January 24th, 2024

This Privacy Policy is meant to clearly inform you about the way Localsensor uses data related to you and about your rights with regard to this data. We therefore ask you to read this Privacy Policy carefully. Should you have any concerns or questions after reading it, please do not hesitate to contact us. Our team is always here to answer questions and to listen to any suggestions you may have for improving our services or policies. You can reach us at: privacy@localsensor.com.

A. ABOUT LOCALSENSOR

Localsensor B.V. is a private limited liability company incorporated under the laws of The Netherlands, having its registered offices in Amsterdam, The Netherlands, at the De Entree 234, Floor 4, Unit 4, 1101 EE. Localsensor is registered with the Chamber of Commerce under number 55634958.

You can always reach our Data Protection Officer at privacy@localsensor.com.

Localsensor is a mobile advertising technology company. We help companies to plan, execute, evaluate and optimize mobile in-app advertising campaigns via our platform (the 'Platform'). Our clients are companies of all sorts that wish to provide you with mobile in-app advertisements that are relevant and of interest to you. Our business partners are publishers that serve you these advertisements in their mobile apps.

B. LOCALSENSOR'S PLATFORM PRIVACY PRACTICES

WHAT PERSONAL DATA DOES LOCALSENSOR COLLECT AND PROCESS?

Localsensor participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. Localsensor's identification number within the framework is 587.

The personal data we use on our Platform includes data regarding your device (device identifier, device location and IP-address) and also data regarding operating system, network provider, device model, the used app and interaction with the served advertisement.

Personal data is only collected and processed after user consent based on the IAB Europe Transparency & Consent Framework.

We are keen to limit the collection of personal data to the bare minimum and make the data less specific to prevent personal identification with the data as much as possible.

FOR WHAT PURPOSES DO WE PROCESS PERSONAL DATA?

On our Platform, we use the personal data we receive from our business partners for limited and well-defined purposes:

Use limited data to select, buy and serve advertising (IAB purpose 2)

Advertising presented to you through our Platform can be based on limited data, such as the apps you are using, your non-precise location, your device type or which content you are (or have been) interacting with (for example, to limit the number of times an ad is presented to you).

Create and use profiles for personalised advertising (IAB purpose 3 and 4)

Information about your activity in apps (such as content you look at) can be used to create segments (for example, information from your previous activity in apps). For this we use pseudonymised identifiers. We do not create or store personal profiles on our Platform.

We will not create segments to such a degree that they can be linked to a single or small group of pseudonymised identifiers.

We will also never allow segments be used to harm your personal interests or interest of a group and we will also never allow segments to be used to limit your fundamental rights and freedoms.

Advertising presented to you by our Platform can be based on segments you appear in, which can reflect your activity in apps (like content you look at).

Measure advertising performance (IAB purpose 7)

Information regarding which advertising is presented to you and how you interact with it can be used to determine how well an advert has worked for you or other users and whether the goals of the advertising were reached. For instance, whether you saw an ad, whether you clicked on it, whether it led you to buy a product or visit a website, etc. This is very helpful to understand the relevance of advertising campaigns.

Develop and improve services (IAB purpose 10)

Information about your activity on our Platform, such as your interaction with ads or content, can be very helpful to improve products and services and to build new products and services based on user interactions, the type of audience, etc. This specific purpose does not include the development or improvement of user profiles and identifiers.

ON WHAT LEGAL BASIS DO WE PROCESS AND USE PERSONAL DATA?

For all purposes the legal basis is user consent.

FROM WHOM DO WE RECEIVE YOUR PERSONAL DATA?

We receive your personal data from our business partners through their programmatic advertising selling platform.

HOW LONG WILL MY PERSONAL DATA BE STORED?

We will retain the data we receive from our business partners only for as long as is necessary for the purposes you gave your consent for. Once the personal data has served its purpose, it is immediately deleted.

For the selection, buying and serving of adverts (purpose 2) and measurement (purpose 7) and development and improvement (purpose 10) we will delete your personal data after 31 days.

For Interest-based Segments (purpose 3 and 4) we will only keep a pseudonymised (hashed) version of your device identifier to link to interest segments. This interest segments we will delete after 12 months. Interest segments don't contain personal data.

HOW DO WE PROTECT PERSONAL DATA?

We take appropriate technical and organizational measures to protect personal data against loss or any form of unlawful use. For example, we limit access to this data only to authorized employees and contractors who need to know that personal data in order to perform their services.

We use hashing, encryption, pseudonymisation and de-identification techniques to ensure that the personal data in our segment database can in no way be linked to you as a person. This allows us to only identify your device for the purposes of providing our service and prevents your data being used to identify you in real life, either by us, our clients or our business partners.

WITH WHOM DO WE SHARE DATA?

We don't share your personal data we receive from our business partners with our advertising clients. We only share aggregate, non-individual data with our advertising clients. Insofar as this is necessary for ad delivery and associated services, we also share data from our database with our publishing partners.

We only share personal data with trusted technology service providers for processing based on GDPR compliant sub-processor contracts.

We will disclose personal data when obligated to do so by law, for instance to law enforcement authorities, our legal advisers or other third parties. We may also disclose personal data if this is necessary to enforce our terms and conditions or to protect our rights. This may also include exchanging data with other companies and organizations for fraud protection.

TRANSFER OF PERSONAL DATA TO COUNTRIES OUTSIDE THE EU

All personal data is stored within the European Union. We will not transfer personal data to outside the European Union.

HOW DO WE PROTECT CHILDREN?

We don't use our Platform to target apps from business partners that are mainly intended for children under the age of 13. We are not knowingly processing personal data of children. If we have accidentally done so and we discover this, we will immediately remove all related (personal) data from our Platform.

C. YOUR RIGHTS

WHAT ARE MY RIGHTS REGARDING MY CONSENT, VIEWING, CHANGING, DOWNLOADING AND DELETING MY PERSONAL DATA?

Your consent is linked to your device identifier on your device. You can, at any time, reset or completely disable your device identifier. Please check your device documentation for instructions.

You can always view and change your consent in the individual apps you are using.

If you wish to know what segments your pseudonymised identifier is associated with on our Platform or if you wish to have this data changed, modified, downloaded or deleted, please contact us via privacy@localsensor.com.

HOW CAN I LODGE A COMPLAINT

Your rights regarding your personal data are of utmost importance to us. If you feel we haven't served you right we would really like hearing from you. You can also lodge a complaint with the Supervisory Authority. For The Netherlands this is the Autoriteit Persoonsgegevens (https://www.autoriteitpersoonsgegevens.nl)

D. MISCELLANEOUS

CAN THIS PRIVACY POLICY BE CHANGED?

We reserve the right to change, update or modify this Privacy Policy at any time at our sole discretion, and will post any new Privacy Policy here. Any such change, update or modification will be effective immediately. Please check our website regularly at https://www.localsensor.com/privacy.html.

QUESTIONS?

If you have any questions, please do not hesitate to contact us via privacy@localsensor.com.