PRIVACY POLICY

INTRODUCTION

Gravy Analytics, Inc. ("Gravy," "we," "us," or "our") values individuals' ("you" or "your") privacy. In this Privacy Policy ("Policy"), we describe how we and our corporate affiliates may collect, use, store, and disclose your information as it relates to:

Our customers ("Customers") are entities that use our Data Services.

Our partners ("Partners") are companies that collect information from individuals, including, their mobile device's location information, and provide that information to us in different data sets so that we can assist our Customers.

By visiting the Website, you agree that your information will be handled as described in this Policy. Your use of this Site is subject to this Policy.

Please note that this Policy does not cover our Customer's use of the information we provide to them. Our Customers may associate the information we provide with additional information they have from other sources and may use this combined information for a variety of purposes, such as, targeted advertising, consumer insights, foot traffic analysis, fraud detection, law enforcement, and national security.

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, please refer to the EEA, U.K., & Switzerland Privacy notice here.

If you are a resident of California, please refer to the California Residents Privacy notice here.

 

WHO WE ARE

Gravy is the leading provider of real-world location intelligence. Our technology verifies mobile consumer attendance at millions of places, points-of-interest, and local events, providing unprecedented insight into consumer activities and interests. We provide our Customers with location-based data services and analytics services based on inferred interests and matching of Location Data (defined below) against place and event data. Our Customers rely on our Data Services to power mobile advertising and marketing campaigns and use our data services to more deeply understand their customers, acquire competitive intelligence, to conduct law enforcement activities and enhance national security, and to provide and improve the services they offer to their own customers.

 

DESCRIPTION OF SERVICES

Gravy collects and process various types of information from mobile devices which we receive from our third-party partners. These third-party partners are owners of mobile applications ("App(s)") or data aggregators who primarily receive data from software development kits ("SDKs") in Apps (SDKs allow developers to embed certain third-party functionality into their own software applications). They may also receive data from (i) WiFi routers, and/or (ii) Bluetooth beacons (these are devices placed in stores that emit Bluetooth signals and collect ID information of smartphones in their vicinity to provide related advertisements to those smartphones).

The data we receive from our Partners includes location data in the form of latitude/longitude ("Location Data"), which is associated with a mobile advertising ID, such as Apple's Identifier for Advertisers ( IDFA) or a Google Advertising ID (Advertising ID/Ad ID). Each mobile advertising ID allows us to identify each unique mobile device and is used by advertisers and marketers to display ads to your device. Using proprietary algorithms, Gravy cleanses, processes and merges the Location Data that we receive from all sources to create a portfolio of Location Data records for each mobile advertising ID. We also may receive other information from our third-party partners about your device, such as IP address and Device User Agent Data (as defined below).

Additionally, we create virtual boundaries, known as geo-fences, around locations of interest, such as shopping centers, restaurants, and events, like professional sports matches, concerts, and county fairs. We then combine the Location Data we receive with our geo-fences, and other information that we create and collect about physical locations, such as venue, hours of operation, and events, and use such combined data to make inferences about the types of activities or events users of such mobile devices enjoy or spend time doing. We use the Location Data and the resulting inferences to provide our Data Services to our customers.

 

OUR DATA PRACTICES

  1. Information We Collect About You
  2. How We Use Your Information
  3. How We Share Your Information
  4. Our Use of Cookies and Other Tracking Mechanisms
  5. Third-Party Links
  6. Security of Your Information
  7. Privacy Choices
  8. Retention
  9. Children

 

1. Information We Collect About You

We collect the following information when you browse or submit an inquiry on our Website, contact us to request information about our products or services, or apply for a job.

Information Category

Description of Information Collected

Identifiers

IP address, and the following information if you choose to provide it to us: name, email address, phone number; job and company information, and state.

Device Information

Your browser type and operating system, time zone setting and location, browser plug-in types and versions.

Internet or Network Activity

Web pages you view, links you click, the length of time you visit our Site, and the webpage that led you to our Site.

Communications Preferences

Your preferences in receiving marketing from us and your communication preferences.

Professional or Employment Information

If you apply for a job, current or past job history or performance evaluations.

 

We collect the following information about you from our Partners and use it to provide our Data Services:

Information Category

Description of Information Collected

Location Data

Precise geolocation data, including latitude-longitude coordinates obtained from Apps via requests to the mobile device operating system which utilizes various mechanisms to derive Location Data, including GPS tools, cell tower triangulation, WiFi data, or other techniques. We do not collect your precise geolocation in real-time. Neither Gravy, nor its third-party data partners determine whether Location Data is received from GPS signals, cell tower triangulation, WiFi data, or by other techniques. The device operating system determines which signal is most readily available to the device and returns the Location Data to the corresponding App provider.

Identifiers

IP address; mobile advertiser ID ("MAID")

Internet or Network Activity

Timestamp, list of Apps from which location signals were received.

Device User Agent Data

Device type; browser family; browser version; operating system; version of operating system; device model number

Demographic Data

Age and gender.

*Bidstream Data*

Gravy Analytics DOES NOT collect mobile advertising bidstream data to support our Data Services. We likewise ask our third-party partners to refrain from supplying data sourced from the mobile advertising bidstream.

 

 

  1. How We Use Your Information

Gravy uses information we collect through our Website for the following purposes:

Gravy uses the information we receive from our Partners to provide Data Services to our Customers. We do not use information collected through our Website to provide our Data Services. Using the information we receive from our Partners, we create a portfolio of your device's Location Data records that are associated with your mobile advertising identification number. We also create virtual boundaries called "geofences" around locations of interest, such as shopping centers, restaurants, and events. We take your device's Location Data and combine it with these geofences, as well as other information noted above, to determine the venues and events you attended and to infer your preferences. As part of our Data Services, we also:

We do not use the information we collect about you to determine employment eligibility, credit eligibility, insurance eligibility, underwriting, or for pricing purposes.

 

 

  1. How We Share Your Information

We may share your information as follows:

 

  1. Our Use of Cookies and Other Tracking Mechanisms

We and our third-party service providers use cookies and other tracking mechanisms to track information about your use of our Site. We may combine this information with other information we collect from you (and our third-party service providers may do so on our behalf).

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.

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 and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.

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 to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site 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.

 

  1. Third-Party Links

Our Site and Services 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.

 

  1. Security of Your Information

We have implemented appropriate administrative, technical, and physical safeguards 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.

 

  1. Privacy Choices

Data Services Opt Out. If you would like to opt-out of our use of your device’s Location Data and other related data we use in our Data Services, you can (a) disable location services on your mobile device, or (b) complete the Opt-Out & Do Not Sell Form. Please note that your opt-out will be specific to the device for which you submit the opt-out request. This means that if you use multiple devices, you will need to opt out each device that you use. In addition, if you re-set your mobile advertising ID, you will need to opt out that device again.

 

Third Party Ad Network Opt Out. We may use third-party network advertisers to serve advertisements on third-party websites or other media (e.g., social networking platforms). This enables us and these third parties to target advertisements to you for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. We may provide these third-party advertisers with information about you.

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, of which we are one.

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. 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.

Email Marketing Opt Out. You may opt-out of receiving promotional communications from us 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.

 

  1. Retention

We retain your personal information for so long as retention is necessary to comply with our legal and contractual obligations, enforce our agreements, and enable us to investigate events and resolve disputes. We store Location Data, Internet or Network Activity, and Device User Agent Data, associated with a particular mobile advertising ID and used for our Data Services, for up to four (4) years, provided, we may retain such personal information for a longer period to the extent it is required for a legal or significant operational purpose, such as for compliance, record-keeping, auditing, safety and security, and error or bug prevention.

 

  1. Children

Our Services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.

 

NAI MEMBERSHIP

Gravy is a member of the Network Advertising Initiative (NAI) and we undergo annual reviews that we adhere to their Strict Code of Conduct. If you wish to learn more about the NAI or about options available to you to opt out of receiving targeted advertising from other third party services that are also members of the NAI, please click here.

 

CONTACT US

If you have any questions or would like to speak with us regarding changes to your personal information, please email us at privacy@gravyanalytics.com, call us at 703.840.8850, or write to us at:

Gravy Analytics

45610 Woodland Rd., Suite 100

Sterling, VA 20166

 

CHANGES TO THIS PRIVACY POLICY

This Policy is current as of the Effective Date set forth above. We will post any changes to this Policy on our Site. If we make any changes to this Policy that materially affect our practices with regard to the 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.

Last Updated: April 2021