Effective as of: January 24, 2024
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. We are not responsible or liable for the practices or privacy policies of those 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 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 take steps to ensure that we do not receive any Observation Data related to healthcare or social assistance facilities.
1.2.3 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; 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. This may include, for instance, vendors we use for web hosting, tech or customer support, billing, data and infrastructure security, data hygiene, validation or enhancement, marketing, or other operational purposes.,
- 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 or those of another person
- 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.
220.127.116.11 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 Advertising 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 Advertising Partners 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.
18.104.22.168 We do not share the precise location of advertising displays with Advertising Partners, and we do not share the precise locations of consumer devices.
22.214.171.124 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 16 months after receiving them. After 16 months they are deleted.
3.2 Precise Location Information
Place Exchange keeps precise location of the mobile advertising identifiers for up to 16 months after receiving it. After 16 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 with us 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. California and Multi-State Privacy Notice: Your Rights and Choices Regarding Your Data
5.1 California Residents and Beyond
5.1.1 An Overview of Your Rights and Choices.
The California Consumer Privacy Act as modified by the California Privacy Rights Act (together the “CCPA”) 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.
Other states, such as Virginia, Connecticut, Colorado and Utah (for instance) (“ Privacy Law States”) have passed similar laws that provide similar rights, upon the respective effective dates or each such law.
California law and the Privacy Law States also grant you the right to direct us not to share (or “sell”) your information.
5.1.2 Access to Your Information.
California and Privacy Law States grant a general right, upon verification of identity, to request access to the data we have about you, including 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.
However, instead of a request to access your personal information, we encourage you to request erasure or deletion as described in Section 5.1.3. If you do make such an access request we may not be able to provide you with certain specific information we have about you, such as precise location coordinates (as opposed to categories or information). This is because we have determined (relying on applicable CCPA regulations) that we cannot verify to a sufficiently, reasonably high degree that the person requesting your location data is the requestor, or if the person in possession of the device or requesting the information is the actual device owner. For instance, a number of people may be temporarily in possession of another person’s phone – e.g. , it may have been stolen, or it may be held temporarily by a partner, friend or work colleague. Our objective is to avoid any situation where the person requesting the information might obtain potentially detailed and sensitive records pertaining to the device’s owner – and we believe California law requires us to do the same. (A recent study concluded that one half of mobile phones were not password protected, making this scenario a very real concern.). Moreover, because we do not collect information such as name, address or email address (which we avoid, to protect consumer privacy), we cannot rely on the more conventional ways to verify the identity of an actual device owner.
Given that, if you are uncomfortable with your device or location information being used in the ways described above, we recommend that you exercise your right to Deletion or Erasure of your information as described in Section 5.1.3 below.
5.1.3 Deletion or Erasure.
Many states, including California or an Applicable Privacy Law State, provide you the right to request deletion or erasure 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 detect, deter or prosecute those breaching it, fix our system in the case of a bug, or provide you with a good or service you have requested.
5.2 How To Request Access or Deletion.
If you would like to request deletion of your information, please use this form.
While we encourage deletion instead of just accessing data, if you would like to request access of your information, please email us at firstname.lastname@example.org. Please note that if you do request access, we may not be able to provide you with some of the information we have about you, including precise location coordinates (as opposed to categories or information), because we do not believe we are able to verify to a sufficiently high degree that the person requesting your location data is you, much less the person in possession of the device or requesting the information is the actual device owner. In any event, 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 access requests within 30 days: if we can’t, or if we need more time, we will let you know.
5.3 What We Have Shared
We sometimes disclose information in ways that may be considered a “sale” in Privacy Law States. For instance, we transfer certain personal information to our Advertising Partners (such as mobile ad identifiers) in a manner that may be considered a “sale” under those laws.
In the past twelve (12) months we have sold identifiers (mobile ad identifiers) by making them available to our Advertising Partners as we describe above.
5.4 How to Tell Us “Do Not Sell My Information”.
Please use this form to opt-out of our use and sharing (or “sale” as it’s sometimes called) of your device’s mobile advertising identifier going forward. Opting-out via this form is also how to exercise your rights of deletion we discuss above in Section 5.2.
You can prevent your device from sharing your device mobile advertising identifier and location information in your mobile device settings. Please visit the Mobile Choices page of the Network Advertising Initiative for detailed instructions on how to prevent your device from continuing to share this information.
5.5 Additional Privacy Rights You May Have in California or Privacy Law States
5.5.1 You May Use an Authorized Agent. You may designate an agent to make requests to exercise your right to access or delete on your behalf. We will take steps both to verify your or your authorized agent’s identity and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a legally sufficient copy of a power of attorney.
5.5.2 Sensitive Personal Information. As we note above, we do receive and use precise geolocation information, but we do not use or disclose it other than for purposes for which you cannot exercise the right to limit under the CCPA.
5.5.3 Right to Appeal. Some state laws (such as in Colorado or Virginia) may permit you to appeal any denials of your rights requests; to do so, contact us at email@example.com and describe in detail why you believe the denial was in error. Please include your full name, email address and a copy of the denial notice you received from us.
5.5.4 Minors’ Data. We do not knowingly “sell” or “share” personal information from minors under 18 years of age. Indeed, we require our Data Providers not to share any information they know is from someone under 18.
5.5.5. Non-discrimination. We do not discriminate against consumers for exercising their state privacy rights.
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.