Last Revised: April 20, 2020
Please take a moment and become familiar with how we collect, use and disclose information.
Intuizi operates a data processing and analysis platform that allows publishers (for example, Apps, Websites, connected TV services and audio services), advertisers, and other third parties (collectively “Clients”) to better understand their users, and prospective users (“Customers”). Specifically, we provide tools and services (together “Services”) that our Clients use to gain insights derived from their own data.
2. OUR SERVICES
Intuizi works with advertisers, publishers and other third parties (“Sources”) who may obtain data from you when you use or visit their websites, applications, partners, and data partners/vendors. Our Sources must de-identify or pseudonymize all data prior to placing it on the Intuizi platform. Intuizi does not possess Personal Data or Consumer Data as those terms are defined by applicable law. Any IDFA or AdID, or any other information that can be used to identify a specific device or person, is de-identified or pseudonymized prior to entering our platform.
Intuizi may create segments, reports, profiles, audiences, insights, conduct statistical analytics, etc. (“Data Derivatives”) from the user data it obtains from Sources to help our Customers identify trends and/or user behavior. Using our technology platform, Intuizi transforms de-identified/pseudonymized user data into actionable insights to enhance user experience and to increase performance for Customers and Clients. We do not attempt to re-identify specific users, nor do we permit any Client to re-identify specific users from data or Data Derivatives on our platform.
As a platform provider, Intuizi 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. Intuizi’s processing of 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 WE RECEIVE FROM SOURCES
3.1 Information about your device
Intuizi may receive some or all of the following information about your device: device type (e.g. smartphone, tablet, etc.), operating system (e.g. iOS, Android, Windows), network provider/feeds, 3G or 4G mobile behavior, mobile browser used, a Client specific anonymous place holder for your: (i) IP address; (ii) iOS Identifier for Advertising; (iii) Advertising ID, and iOS Identifier for vendors, identifier for application, application version, model, manufacture of device, OS version of device, session start/stop time, time zone, network status such as WiFi, a non-specific 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.
Intuizi does not directly interact with end users. To the extent, any WiFi identifier information is obtained through Intuizi or its Affiliate’s owned and operated applications or software development kit, Intuizi ensures that it infers location only if the application providing such data sets have a user’s active, informed consent to do so. For data sets obtained from a third party Source, the responsibility to obtain consent remains with the Source and Intuizi 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 informed, active consent from a Source).
3.2 Demographic data, subscription data 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 unauthorized disclosure of such personal information in our custody.
4. HOW WE USE YOUR INFORMATION
Intuizi 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. Intuizi may sell, license and/or otherwise transfer Data Derivatives on an aggregated and anonymized format to its Clients in performing its Services. Our Clients may also use Data Derivatives for serving interest-based advertising, or other uses allowed by applicable law.
5. WHO WE SHARE INFORMATION WITH
(a) Intuizi shares Data Derivatives with our Clients as part of our Services. Any Client’s use of the information we share with them will be governed by their privacy policies.
(b) We may also share your information with Intuizi Affiliates so that we can improve our Services and otherwise serve our Clients better.
(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.
Intuizi 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 WE KEEP INFORMATION SECURE
Intuizi uses reasonable technical and organizational measures to protect the information it receives 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 WE KEEP INFORMATION
Intuizi may retain information for a period of up to twelve (12) 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 four (24) months.
Intuizi 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, Intuizi 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
Other than through your interaction with our website (which is covered under Paragraph 12 below) Intuizi does not directly interact with end users and therefore, does not collect your information directly. You should refer to the privacy policies of the respective Sources that you may interact with, to exercise your opt-out options.
You may also reach out to email@example.com 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 (which is the case in all instances), we will not be in a position to address your request.
9. PRIVACY OF CHILDREN
Intuizi 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 INTUIZI WEBSITE
12.1 WHAT INFORMATION DO WE COLLECT?
If you choose to create an account on the Intuizi 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 Intuizi to contact you for the only purpose of engaging with Intuizi or Intuizi or Affiliates as a business partner. This data is not shared by Intuizi with any third parties.
12.2 HOW DO WE USE THE INFORMATION WE COLLECT FROM OUR WEBSITE?
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), personalize 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 analyze 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 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 one hundred percent secure.
12.4 HOW LONG WE 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.
13. CONTACTING US
Data Protection Officer
8816 Lovett Ave
Orlando, FL 32832, United States.
14. INTERNATIONAL DATA TRANSFERS
Intuizi may transfer de-identified or pseudonymized data derived from you by Sources using our platform to countries other than the one in which you live. For additional information about data transfers please contact Intuizi’s Data Protection Officer at firstname.lastname@example.org.
15. DATA CONTROLLER AND PROCESSOR
Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, our Clients are the controller of their respective Customer Data. In general, Intuizi is the processor of Customer Data and the controller of other information.
Intuizi, Inc., is the data controller for any personal data provided directly to us by a user or otherwise collected by us directly from a user.
16. YOUR RIGHTS UNDER EU LAW AND OTHER JURISDICTIONS
Data protection law in certain jurisdictions differentiates individuals located in certain countries, including the European Economic Area, who have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to information, as well as to seek to update, delete or correct this information. You can contact privacy@Intuizi.com for assistance.
To the extent that Intuizi’s processing of data sourced from you is subject to the General Data Protection Regulation, Intuizi relies on its legitimate interests, described above, to process your data. Intuizi may also process other information that constitutes your personal data for direct marketing purposes and you have a right to object to Intuizi’s use of your personal data for this purpose at any time.
Subject to applicable law, you also have the right to (i) restrict Intuizi’s use of information that constitutes your Personal Data as that term is defined by GDPR and (ii) lodge a complaint with your local data protection authority. If you are a resident of the European Economic Area and believe we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you may direct questions or complaints to your local data protection authority.