Privacy Policy

EFFECTIVE DATE: April 27, 2018

Gravy Analytics, Inc. (“Gravy,” “we,” “us,” or “our”) values our users’ privacy (“you” or “your”). In this Privacy Policy (“Policy”), we describe our privacy practices with regard to:

1. The Information We Collect as a Service Provider to Provide Our Data Services

Gravy provides its customers with location-based data services, analytics services, and audience segments which include customer behavior and insights analytics, attribution reporting, and foot traffic analytics. Although our Data Services vary based on the particular service or customer, a key component of our Data Services is the collection and use of precise location data, and the licensing of derivative data products to our customers.

We collect precise location data from (i) users of our App, (ii) our third-party partners, and (iii) our customers. We combine this data with other information that we create and collect about physical locations, such as geo-fences, points-of-interest and venues, and category of points-of-interest or venue, hours of operations, and events. Additionally, Gravy, its partners, and our customers may collect location data through owned and operated mobile applications, from end users who opt-in to the collection of such data and share that data with us using a pseudonymized identifier, for each mobile device, known as a mobile advertising ID (“MAID”). Each MAID allows us to identify each unique mobile device. Our partners may also aggregate and collect location data from end-users who opt-in to the collection of such data through mobile applications and advertising services owned and operated by their partners and customers.

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 MAID. We also create a virtual boundary, known as a geo-fence, around locations of interest, such as shopping centers, restaurants, points-of-interest, and events, like professional sports matches, concerts, and county fairs. We compare the location data records with our geo-fences to generate visitation, attendance, and audience data for each mobile device.

We use the resulting visitation, attendance and audience data to provide our Data Services. The resulting data is used for, amongst other things, location analytics, customer behavior analytics, and targeted advertising, or for law enforcement and national security purposes.

2. Website and Mobile Application Privacy Policy

In this section of this Policy, we describe the information that we collect about you when you use our Site and/or our App, and how we use and disclose that information. By visiting the Site, or 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.

A. The Information We Collect About You

i. Through your Use of the Site

In general, you may visit the Gravy Site without giving us any information about yourself, except if you contact us via our Site. If you contact us or submit an inquiry via our Site, we collect your name, email address, phone number, company information, and any information you include in your message to us.

Additionally, we automatically collect information about your use of the Site from your mobile phone, tablet, desktop or laptop computer, or other consumer electronic device that you may use to access the Site. Collection of such information may occur even if you have not otherwise submitted any information to us. Such information may include the following:

We collect the above information through cookies, web beacons. Please see the section “Cookies and Other Tracking Mechanisms” below for more information on our use of cookies and other tracking mechanisms. We may use this automatically collected data for research and internal purposes, including improvement of our Site so that it is more user friendly and accessible to you.

ii. Through Your Use of the App

In order to access specific features of our App, you will need to register with us. If you register for our App, you will need to do so using your Facebook or Google login credentials. When you register with our App, we access your Facebook or Google profile identifier to create a unique user profile for you and register you as a pseudonymized App user, using a hashed and encrypted token. The App does not store, nor transmit any content from your Google or Facebook public profile.

Gravy has no control over how any third-party social networking site uses or discloses the information it collects about 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 may collect the following information from you through your use of the App:

B. How We Use Your Information

We use your information for the following purposes:

C. How We Share Your Information

We may share your information, as follows:

We may also share information in the following circumstances:

  • Business Transfers. If we are acquired by or merged with another company, if some or all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
  • In Response to Legal Process. We may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
  • To Protect Us and Others. We may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or act regarding illegal activities, suspected fraud, potential threats to the safety of any person, violations of our Terms of Use or this Policy, or as evidence in litigation in which Gravy is involved.
  • Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.
  • D. Our Use of Cookies and Other Tracking Mechanisms

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

    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.

  • Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site.
  • Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity.
  • Cookies on our App. While the App does not use or contain cookies, the App supports URL loading in a WebKit WebView (a UI component used for browsing web pages) and such URLs may save cookies within our App storage. Gravy does not have control over such URLs, but uses 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 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.

    Third-Party Analytics. We use automated applications, such as Google Analytics, to evaluate usage of our Site and our App. We use these tools to help us improve our Site and App performance, and user experiences. These entities may use cookies and other tracking technologies to perform their services. We share information regarding your use of the App and Site, such as how many pages you have viewed, how long you have been logged into our App, where you clicked, etc., with these third parties.

    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.

    E. Third-Party Ad Networks

    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. These third-party cookies and other technologies are governed by each third party’s specific privacy policy. 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.

    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.

    F. Third-Party Links

    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

    G. Security of Your Information

    We have implemented appropriate and 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.

    H. E-mail Communications

    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.

    I. Children Under 13

    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 information, we will delete such information from our systems.

    3. Opt-Out

    If you would like to opt-out of our use of your device location data for our Data Services, you may disable location services on your mobile device or follow the instructions below:

    To opt-out of our use of location data associated with your mobile device, please complete the Mobile Advertising Opt-Out Form.

    4. Contact Us

    If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at:

    Gravy Analytics
    45610 Woodland Road, Suite 100
    Dulles, VA 20166
    (703) 840-8850

    info@gravyanalytics.com

    5. Changes to this Policy

    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 “About,” and clicking on “Privacy Policy.” 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 or notifying you of the change in our App.