Effective as of: August 31, 2022
1. Information Place Exchange Receives in Connection with the Services
1.1 Place Exchange Receives Consumer Data from Data Providers
We do not collect any information directly from consumers or their devices. All the data we receive comes from data providers that collect information from consumers’ mobile devices via an app or other service (“Data Providers”).
1.1.1 Click here to learn about the data collection practices of our third party Data Providers.
1.2 Place Exchange Receives Mobile Advertising Identifiers and Location Information
Our Data Providers send us three data elements, which we call an “observation” when combined. Observations consist of (1) the mobile advertising identifiers of devices that are near public displays integrated with the Services, (2) the precise locations of those devices (e.g., latitude and longitude), and (3) the time of each observation (collectively, “ Observation Data”). We receive the Observation Data only after the advertising has been displayed, and we do not use Observation Data, or allow our Publishers or Advertising Partners to use it, to target specific individuals with advertising in public space.
1.2.1 Place Exchange does not receive any information about individual consumers or their personal devices other than Observation Data (nor do we rely on beacon or other forms of indirect interaction).
1.2.2 We honor user choice. If we receive an opt-out signal in connection with Observation Data, we will not share that Observation with any third party, including Advertising Partners; in any event, Place Exchange does not use mobile advertising identifiers or any other device or user-specific information to target ads on public displays to specific devices or individuals.
2. How Place Exchange Uses and Shares Information
2.1 How Place Exchange Uses Information
We may use the information we receive to:
- Enable our Advertising Partners to measure the effectiveness of advertising delivered on public displays through the Services, and help them plan future placement of advertisement based on that measurement,
- Operate, maintain or improve the Services, including the delivery of advertising on public displays, administration, internal operations, troubleshooting, data analysis, testing, research, statistical and survey purposes,
- Manage the Services,
- Comply with laws and regulations, and
- Maintain the security of the Services.
2.1.1. Place Exchange does not use mobile advertising identifiers or any other device or user-specific information to target ads on public displays to specific devices or individuals (sometimes referred to “Personalized Advertising”“Interest-based Advertising” or “Retargeting”), nor does it enable Publishers or Advertising Partners to do so.
2.2 How Place Exchange Shares Information
2.2.1 Sharing in General.
Place Exchange may share any information with:
- Service providers and sub-contractors to the extent reasonably necessary to provide, manage, or improve the Services,
- A third party with whom there is a legal obligation to share information.
We may also share personal information if we believe it would be necessary to:
- Comply with the law or with legal process
- Protect and defend our rights and property
- Protect against misuse or unauthorized use of the Services.
We require a valid subpoena, court order, or other valid legal demand in order to process a governmental information request. While we are legally obligated to respond to lawful requests for customer-related information, we are also committed to protecting your privacy. We carefully review all legal requests we receive and actively push back on requests that are procedurally deficient, overly-broad, or otherwise improper or invalid.
2.2.2 Sharing with Advertising Partners.
184.108.40.206 Place Exchange obscures the Observation Data prior to sharing it with Advertising Partners. Specifically, Place Exchange shares with Advertising Partners the mobile advertising identifiers of devices that were near advertising displays, but we only provide the general area (about five football fields in any direction) of the location of the displays, so that Advertisers Partners do not know the precise locations of where ads were displayed.
Advertising Partners use the information to report on, analyze, and measure the delivery and effectiveness of advertising delivered on public displays through the Services. For example, our Advertisers may analyze the information we give to them to understand if a device exposed to an ad is likely to make a later purchase or appear in certain types of locations: that analysis will allow them to plan their advertising campaigns and select the locations and contexts where their advertisements will be displayed.
220.127.116.11 We do not share the precise location of advertising displays with Advertising Partners, and we do not share the precise locations of consumer devices.
18.104.22.168 We honor user choice. If we receive an opt-out signal in connection with Observation Data, we will not share that Observation (obscured or not) with any third party, including Advertising Partners.
3. How Long We Keep Information
3.1 Mobile Advertising Identifiers
Place Exchange keeps mobile advertising identifiers for 13 months after receiving them. After 13 months they are deleted.
3.2 Precise Location Information
Place Exchange keeps precise location of the mobile advertising identifiers for up to 13 months after receiving it. After 13 months it is deleted.
4. Place Exchange’s Website
4.1 If visitors to the Place Exchange website fill out a feedback form, sign up for an email list or choose to communicate in another way, their information will be collected in order to respond to the request, feedback, or question. That information will not be shared with any third party for their own use.
4.2 Information may also be collected about the IP address, as well as the computer, mobile device, or other device used to visit the Place Exchange website.
4.3 Place Exchange’s website uses “cookies,” web beacons, tags and scripts, and other similar technologies to help understand website visitors. The website does not respond to browser-based “do not track” signals.
4.4. You can find out more about Google Analytics cookies. You can avoid the use of Google Analytics relating to your use of the Place Exchange website by downloading and installing the Opt-Out Browser Plugin.
5. Your Rights, and the Choices You Have Regarding Your Data
5.1 California Residents and Beyond
5.1.1 An Overview of Your Rights and Choices.
The California Consumer Privacy Act provided California residents with certain rights and choices about the collection, processing, and use of their personal information. In particular, if you are a California resident, you have the right to (i) know and see the information we have collected or received about you in the last 12 months, and (ii) request erasure or deletion of your information. California law also requires that you have the right to direct us not to share (or “sell”) your information. The law requires us to make these rights clear for all Californians, but we offer these same choices and tools to everyone, regardless of residency. If you do not live in California, you may not have been granted these same rights by law, but we will honor your requests nonetheless.
5.1.2 Access to Your Information.
You have the right to know and see the information we have collected or received about you, including the right to know and see the categories of information (which we have detailed in Section 1), the categories of the sources (you can see a list of our Data Providers), and the specific pieces of information collected or received.
5.1.3 Deletion or Erasure.
You also have the right to request erasure or deletion of your information. Your right to request deletion of your information also includes the right to direct our service providers to do the same. However, please be aware that there are exceptions to our obligation to delete, including when it is necessary for us or a third party to protect your security or prosecute those breaching it, fix our system in the case of a bug, or provide you with a good or service.
5.2 How To Request Access or Deletion.
If you would like to request access or deletion of your information, please email us at email@example.com. Please note that we have a responsibility to verify your identity before we respond to an access request: we want to be sure that we are disclosing your information only to you. Because most of the information we retain only identifies a mobile device and can’t identify you individually, you will have to verify and possibly attest that you are entitled to any information. We will try to respond to your requests within 30 days: if we can’t, or if we need more time, we will let you know.
5.3 “Do Not Sell My Information”.
We do not consider our sharing of your information as “selling” in the traditional sense of the word. However, as we detail here, we do transfer certain of your information to our Advertising Partners, and they may be doing so, as that term is defined by California law.
You can limit the sharing of both your device mobile advertising identifier and your location information in your mobile device settings. Please visit the Mobile Choices page of the Network Advertising Initiative for detailed instructions on how to opt-out on mobile devices. Because we do not have a direct relationship with consumers, we cannot offer these tools directly.
6.1 We are members of the Network Advertising Initiative (NAI) and adhere to its Code of Conduct.
6.2 Consumers may limit the sharing of their device mobile advertising identifier, as well as location information, in their mobile device settings. Please visit the Mobile Choices page for detailed instructions on how to opt-out on mobile devices. Place Exchange does not have a direct relationship with consumers and cannot offer these tools.
6.3 Publishers and Advertising Partners may have their own policies that govern how they collect, use, and share data. These policies may differ from the practices and policies described here. View the privacy policies of Place Exchange’s Data Providers.
6.4 The Place Exchange Services are offered in the United States; the privacy practices set forth here are governed by the laws of the United States.