EFFECTIVE DATE: July 26, 2017
Gravy provides customers with location-based audience segmentation and analytics services. Although our services may vary based on the particular service or customer, a key component of our service is the collection and use of precise location data. We create geo-fences around certain locations, such as shopping centers, restaurants, events, and points of interest to measure consumer interest. A geo-fence is a virtual boundary around an area, like a retail store, that sends a signal to our software when a mobile device’s GPS or RFID signal enters the boundary area. We collect precise location data from third party sources and combine this data with other information that we collect about you. For example, our customers may collect location data through their own mobile applications, and share that data with us. Depending on our customers’ requirements, we may associate the location data we receive from them with a unique device identifier assigned by the customer; our customers may assign this unique identifier to multiple devices that our customer has associated with your use of their services. We combine the location data that we receive from our customers with our geo-fences and data about events in the area and turn it into audience segment data. In other situations, we may obtain location data from third-party suppliers, and use that data in combination with other data that we collect.
We use the data we receive to provide our analytics service, to create geo-fences around customer-identified locations, to provide customers with information about event attendance, to create audience segments based on event attendance and consumer behavior information, and for other purposes as permitted by law and defined by the customer.
The type of data that we provide to our customers and how our customers use that data may vary by customer. Our customers may use the aggregate data in accordance with their own privacy policies and as permitted by law, which may include advertising, including targeted advertising, analytics, or law enforcement purposes. Please refer to our customers’ privacy policies for any choices they may offer about opting-out of how they may share information with us; alternatively, you may disable location services on your mobile device.
In this section of this Policy, we describe the information that we collect about you when you use our Site and our App, and how we use and disclose that information. By visiting the Site, using or downloading the App, you agree that your information will be handled as described in this Policy. Your use of our Site or App, and any dispute over privacy, is subject to this Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes, which are incorporated by reference into this Policy.
The Information We Collect About You
Information We Collect Directly From You
Information We Collect Automatically
How We Use Your Information
How We Share Your Information
Third Party Analytics
Third-Party Ad Networks
Security of My Personal Information
What Choices Do I Have Regarding Use of My Personal Information?
Children Under 13
Changes to this Policy
We collect information about you, including name, address, email address, telephone number, computer IP address, and other similar information that relates to or identifies you as an individual (“Personal Information”), directly from you and from third parties, as well as automatically through your use of our Site or App.
i. Information that We Collect About You from Social Networking Sites. If you choose to log into our App through your Facebook or Twitter account, we collect the following information:
Facebook. We will request permission to your public Facebook profile information (which may include your name, profile picture, gender, networks, user IDs, list of friends, date of birth, email address, and any other information you have set to public on your Facebook account).
Twitter. You may share events via your Twitter account, but we will not collect any information based on such postings.
We store the information that we receive from Facebook and Twitter with other information that we collect about you.
Any third-party social networking site controls the information it collects from you. For information about how they may use and disclose your information, including any information you make public, please consult their respective privacy policies. We have no control over how any third party site uses or discloses the Personal Information it collects about you.
ii. Information We Collect Automatically. We automatically collect information about your use of the Site and App through cookies, web beacons, and other technologies, including technologies designed for mobile apps, which may occur even if you have not registered or otherwise submitted any information to us. We combine this information with other information we collect about you. Please see the section “Cookies and Other Tracking Mechanisms” below for more information. We collect the following information from your use of our Site and App, respectively:
We use your information, including your Personal Information, for the following purposes:
We may share your information, including personal information, as follows:
We may also share information in the following circumstances:
Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site, while others are used to enable a faster log-in process or to allow us to track your activities at our Site. There are two types of cookies: session and persistent cookies.
Cookies on our App. While the App does not use or contain cookies, the App nonetheless supports URL loading in a WebKit WebView (a UI component use for browsing web pages) and such URLS may save cookies within our App storage. Gravy does not have control over such URLS, however, we do use App libraries from Twitter, Facebook, and Localytics which have access to our App storage and which may use the cookies stored therein. Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse certain areas of the Site, but some features may not function.
Clear GIFs, pixel tags, and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site and App to, among other things, track the activities of Site and App visitors, help us manage content, and compile statistics about Site and App usage. We and our third party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.
Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Third Party Ad Network section below.
Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.
Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.
Our Site and App may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.
We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
I.As an App user, you may modify, alter, or delete Personal Information that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the App for a period of time after such update, modification, or deletion. What Choices Do I Have Regarding Use of My Personal Information?
We may send periodic promotional emails to you. You may opt-out of such promotional communications by following the opt-out instructions contained in the e-mail. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails about recommendations or other information we think may interest you, we may still send you e-mails about your account or any Services you have requested or received from us.
Our Site and App are not designed for children under the age of 13. If we discover that a child under the age of 13 has provided us with Personal Information, we will delete such information from our systems.
If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at:
1602 Village Market Blvd, Suite 230
Leesburg, VA 20175
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site and App. This Policy is accessible in the App by going to “Settings,” and clicking on “Legal Information.” If we make any changes to this Policy that materially affect our practices with regard to the Personal Information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site or App.