Hi, and welcome to our Privacy Policy. Below you’ll find some legal language that may sound a bit heady, but we’ve made a concerted effort to break down everything that we do in simple, straightforward terms. As consumers and end-users ourselves, privacy is important to us and we know it is to you as well. If you have any questions about the below, please do not hesitate to reach out to us at privacy.local@gmail.com.
Effective Date: May 25, 2018
PRIVACY POLICY
Welcome to the website (the “Site,” which includes any mobile applications, mobile sites and tablet applications) of Post T Productions, LLC, d/b/a Local (together with its successors and assigns, “Local,” “we,” “us,” and/or “our”). This Site is operated by Local and has been created to provide information about our company, our mobile application, and our features (i.e. functions Local has developed including the ability for users to save places, follow people, and create lists), and content (i.e. includes the ability to post Local tips) (all, collectively, the “Services”) to our Site visitors and users (“you,” “your”).
This Privacy Policy sets forth Local’s policy with respect to information including personally identifiable data (“PII”) and how we collect, use, and process that information as well other information (“Data”) collected from the Site.
Please read this Privacy Policy carefully. By using or accessing the Services, you acknowledge that you have read, understood, and agree to be bound to all the terms and conditions of this Privacy Policy, and the “Terms of Service” or other customer agreement between you and Local that is applicable to the particular Services you are using or accessing (collectively, “User Agreements”).
If you do not agree to this Privacy Policy and the applicable User Agreement, please exit, and do not access or use, the Services.
We have kept this simple for your understanding, but if you’re not familiar with terms like “cookies” or “IP addresses,” feel free to contact us. Your privacy is very important to us, so please take the time to get to know our practices.
The following chart is a breakdown of the Services we offer, the Data we collect, and the reasons we collect such Data:
Service | Data | How data helps provide the service |
---|---|---|
Logging In | Name, Email, Photo, IP address | We use third party authentication like Google and Facebook to help us with end-user account management, expedite your sign in process, and provide added security and prevent abuse during sign-up. |
Crash Reporting | Instance IDs, Crash Traces | Crash reporting is essential to ensuring we are providing the best Services to you as we can. We associate crashes with all of the Services within the App and require Instance IDs (generally used provide a unique ID for authentication and security, which is anonymized) to measure the number of users who may be impacted by a crash. We use this information to promptly debug the App for optimized functionality. |
Performance Monitoring & Predictions | Instance IDs | We use Instance IDs to observe anonymized behavior throughout the App. Examples include information that you directly provide to us, which may include photos you choose to upload to your account, search history, who you follow, places you save to a list, names of lists you created, location, comments or tips you make, and any other Data you volunteer to us as you navigate throughout the App. This helps us not only optimize user-flow over time, but also to allows us to determine trends and develop better and new ways we can offer you Services. |
Realtime Database | IP addresses, User Agents | Maintaining a database allows us to log activity over a period of time, which helps us understand usage trends and platform breakdown. This is something we use to help optimize Services. |
Analytics | Mobile IDs, IDFVs, Instance IDs, Analytics App Instance IDs | We use Google Analytics to provide us with analytics and attribution information. Specifically for IDFVs, an alphanumeric string is generated that uniquely identifies a device to any potential third party vendor. This may include things like, number of users and sessions, session duration, operating systems, device models, geography, App updates, etc. We use analytics to help us better understand how you're using the App and, again, to better provide our Services to you. |
Location | Magnetometer or barometer, Bluetooth data, Beacon data, Wi-Fi access points, GPS data, Cell tower data | When you enable Location Services within the App, we use it to help determine your geographic location. This helps us show you establishments near you, optimizes your search services, and better apply any filters you set within the App. Other than in an anonymized, pseudonymized or aggregated form, your location is never shared with others, except with your consent or as permitted under this Privacy Policy. If you have opted-in and want to opt-out, you may remove your permission at any time by going into your operating device settings and toggling off background sharing. |
Communication With You
We may use your Data to communicate with you, including by email or in the App, about new product offerings, updates to the Services, or anything else we think may be of interest to you.
Data That May Be Shared With Other Users
When you use the Services, your authorized friends may see some of your PII and Data, such as your name, email address, profile photo, links, a list of your friends, your saved places and lists, and any content, comments or tips that you post. When you communicate on or through the Services, such as saving a location to a list or leaving a tip, your friends may see this Data, too.
Publicly available Data such as the Data available in your user public profile, tips, likes, saves, public photos, lists that you create and follow, and lists of friends and/or followers may be searchable by search engines and be shared with or disclosed to third parties.
We neither rent nor sell Data about users unless anonymized. Though, as described more fully in this Privacy Policy, we may license or otherwise provide certain other Data to third parties, provided we have received your consent to do so.
Protection Of Our Rights
We may use your Data to protect the rights, property or safety of Local, the Services, our users and employees, or any third party. For example, we may use your Data if we need to enforce or apply our Terms of Service or Policies.
Other times
We may share your Data when we believe in good faith that such release is necessary to comply with law or a legal process, including laws outside your country of residence; to protect our rights, property, or safety of Local, our employees, the Services and others.
We may share your Data as part or in anticipation of a business sale, merger, consolidation, investment, change in control, transfer of substantial corporate assets, reorganization, liquidation, or similar business transaction or corporate event.
Data That May Be Shared With Third Party Partners And Service Providers
A key purpose of the Services is to help users discover and learn about locations and brands that are relevant to them, and for these organizations to provide information about themselves, and their Locations to users, as well as potentially reward users when they visit their Location through offers or specials provided to you in compliance with applicable law. When you visit a Location, your visit may be shared with that Location so they can provide superior products and services to you. Sharing your visit means providing the Location with your user name, profile photo and the handles for any social media accounts you have connected with your Local account (e.g., your Google ID) at the time you save a Location.
When we partner with a business, we may share Data with them but only in aggregate or in some cases, we may share a non-identifying ID such as an advertising ID or a hashed identifier (“pseudonymized”). When we share Data in a pseudonymized form, a unique identifier (like an IDFV) is shared so that our partner can measure conversion as to whether an individual has seen its ad, visited its website, or went to their brick and mortar location. We may also share or disclose aggregated, pseudonymized, and/or anonymous Data to other third parties, including Local Users you may follow or other vendors, for analytical or other purposes.
Except as permitted under this Privacy Policy, we will only share your PII with your consent. For example, we sometimes enter into relationships with partners to offer contests and promotions through the Services. For example, we may partner with a brand to have a contest to win a prize and if you enter the contest, we may share your email address and/or other necessary PII with such brand, with your consent. In these cases, we will only share Data that is necessary with our partner.
Accessing and Deleting My Data
Each of your saved places and lists using the Services is saved to your "List History," which allows you and your friends to look back at the locations you have saved since you created your account. You can delete any of your saved places from the profile section in the App. If for any reason you ever decide to delete your account, your account and your PII will be deleted from our database.
You may access and update your Data at any time through the “Edit Profile” or “Settings” tab in your Local account. To view every Location that you have saved, you may access this Data in the profile page on the App.
You may also delete your account at any time on our Sites by clicking on the Delete Your Account link in your Privacy Settings page. If you delete your account, your profile, including your saved places, tips and photos will be removed from the Services, and you will no longer be able to access such Data. We may not be able to restore your account once it has been deleted. Deletion of your account may not be immediate. Residual copies of your Data or posts may remain on backup media for a short period of time thereafter. Additionally, we may store certain Data that is not personal, i.e. does not directly identify you, in our internal systems, which we may use with vendors. We may also retain Data as required by applicable law and we will not delete any Data that is not personal, i.e., has already been anonymized.
If you have questions about accessing, updating, or deleting your Data, please email privacy.local@gmail.com.
Privacy Choices and Opting Out
Opting Out of Behavioral Advertising and Tracking Tools
You can opt-out of certain Behavioral Advertising activities by doing one or more of the following. Please note that you will need to opt-out of each browser and device for which you desire to apply these opt-out features.
- Service Provider Opt Out: You can opt-out directly from some Advertising Service Providers and providers of Tracking Tools by using their opt-out tools. Some of these service providers, and links to their opt-out tools, are:
- Google Analytics: with a privacy policy at http://www.google.com/policies/privacy/partners/ and opt out at https://tools.google.com/dlpage/gaoptout.
- Industry Opt Out Tools: Some Advertising Service Providers or providers of Tracking Tools may participate in the Network Advertising Initiative's (NAI) Opt-Out Tool (http://www.networkadvertising.org/choices/) and/or the Digital Advertising Alliance (DAA) Consumer Choice Page (http://www.aboutads.info/choices/), and you can opt-out of certain services and learn more about your choices by visiting the links included there. Users in the EU can visit http://www.youronlinechoices.eu/ for more information about your choices and to opt out of participating service providers.
- Web Browser Controls: You can prevent the use of certain Tracking Tools, such as cookies, on a device-by-device basis using the controls in your web browser. These controls can be found in the Tools > Internet Options (or similar) menu for your browser, or as otherwise directed by your browser’s support feature. Through your web browser, you may be able to:
- Delete existing Tracking Tools
- Disable future Tracking Tools
- Set your browser to provide you with a warning each time a cookie or certain other Tracking Tools are being set
- Mobile Opt Out: Your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of mobile app information for Behavioral Advertising. You may also opt-out of certain Tracking Tools on mobile devices by installing the DAA’s AppChoice app on your mobile device (for iTunes, visit https://itunes.apple.com/us/app/appchoices/id894822870?mt=8, for Android, visit https://play.google.com/store/apps/details?id=com.DAA.appchoices&hl=en). For more information, please visit http://support.apple.com/kb/HT4228, https://support.google.com/ads/answer/2662922?hl=en or http://www.applicationprivacy.org/expressing-your-behavioral-advertising-choices-on-a-mobile-device, as applicable.
- Do Not Track: Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. The Service does not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Service and after you leave our Service.
Please note that when you opt out of interest-based ads, you will still see ads, but they will no longer be based on your interests or behavior. After you have opted out, we will no longer use any PII collected from you on that particular browser or device for advertising purposes. We will also be unable to connect that device or browser to a different device or browser.
Information Shared with Third Parties: Except as set forth in this Privacy Policy, you will be notified when your PII may be shared with third parties, and will be able to prevent the sharing of this information. To the extent permitted or required by applicable law, you can opt-out of having your information shared with a third party that is not our agent, by contacting us at privacy.local@gmail.com. However, please note that opting-out of information sharing or collection may affect your ability to use some features of the Services.
How We Use Cookies and Similar Technologies
We may use technologies like cookies, pixels, web beacons, local storage and other identifiers on our Sites, in our emails, and within our App to provide you with a range of products and services. We use these technologies for a number of purposes, such as for authentication, security, preference settings, advertising and analytics. We sometimes work with advertisers or other partners, and advertising service providers to serve ads to you on the Services, or a third party website or app, that may be relevant to you based on your interaction with the Services, including places you have saved.
Third Party Access to Data
Below are the ways in which we may collect, use and share Data about individuals who are not Local Users.
Media Products
We, our partners, and advertising service providers may receive Data from unaffiliated apps and websites, advertising exchanges, ad platforms, ad networks or from our partners, which we, our partners and advertising service providers may use to send interest-based advertising. The Data collected for this purpose may include Data such as activity when using the Services or on unaffiliated websites and apps, or Data received from web browsers or operating systems such as browser types and settings, the operating systems, device models, carriers, location information, IP address, mobile device and advertising identifiers (e.g. Apple IDFA or Google Advertising ID), as well as cookie information, pixel or other similar technology.
When we partner with a business, PII is not shared with them. We will only share Data in aggregate or in some cases, pseudonymized form. When we share Data in a pseudonymized form, a unique identifier is shared so that our partner can measure conversion as to whether an individual has seen its ad, visited its website, or visited their brick and mortar location.
We may collect data about individuals acting in their professional capacity as a representative of a third party developer, vendor, partner or enterprise customer. We may collect their names, job titles, phone numbers, email addresses and/or billing addresses (of their organization), so that we can contact and interact with these organizations in relation to the contracting process, billing, and/or promotions. We do not combine data from these individuals with any Data about users of our Services.
We may share data we collect about these individuals with service providers, vendors and contractors to provide or perform services on our behalf, such as providers that help us manage customer relationships, sales, and marketing for Local. Our service providers, vendors and contractors will be subject to binding contractual obligations to: (i) only process this data in accordance with our prior written instructions, and not use the data for their own purposes; (ii) use measures to protect the confidentiality and security of the data; (iii) comply with additional requirements under applicable law.
Your Legal Rights
Subject to applicable law, you may have a number of rights regarding the processing of your PII, including:
- the right to request access to, or copies of, your PII that we process or control, together with information regarding the nature, processing and disclosure of that PII;
- the right to request rectification of any inaccuracies in your PII that we process or control;
- the right to request, on legitimate grounds:
- deletion of your PII that we process or control; or
- restriction of processing of your PII that we process or control;
- the right to object, on legitimate grounds, to the processing of your PII by us or on our behalf;
- the right to have your PII that we process or control transferred to another data controller, to the extent applicable;
- where we process your PII on the basis of your consent, the right to withdraw that consent; and
- the right to file a complaint with a Data Protection Authority regarding the processing of your PII by us or on our behalf.
- This does not affect your statutory rights.
To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Privacy Policy, or about our processing of your PII, please use the contact details provided in this Privacy Policy.
Security
We use industry standard physical, technical, and logical security measures to protect your Data. We endeavor to safeguard your Data to ensure that it is kept secure. However, we cannot guarantee the security of Data in an account from unauthorized entry or use, hardware or software failure, and other factors. If you use the Services on public or shared networks (e.g. public wifi), we cannot ensure the security of your account.
Children under 13
The Services are not directed to individuals who are under 13 years of age. We do not knowingly collect any Data from children under 13. If you are under 13 years of age, please do not use the Services. If you notice or suspect that a user is under 13, please contact us immediately at privacy.local@gmail.com.
Data Retention
The criteria for determining the duration for which we will keep your PII are as follows: we will retain copies of your PII only for as long as is necessary in connection with the purposes set out in this Privacy Policy, unless applicable law requires a longer retention period. In addition, we may retain your PII for the duration of any period necessary to establish, exercise or defend any legal rights.
International Users
Our App and all of our data, including your Data, are hosted on servers in the United States. If you are using or accessing the Services from outside of the United States, your Data will be transferred to, processed and stored in the United States. As a result, United States federal and state governments, courts, or law enforcement or regulatory agencies may be able to obtain your Data through laws applicable in the United States. United States laws may not offer the same privacy protections as the law of your jurisdiction.
Changes to this Privacy Policy
Local may amend this Privacy Policy from time to time. We encourage you to regularly check this page to review any changes we might make in accordance with this Privacy Policy. If we make material changes in the way we use your Data, we will notify you by posting an announcement on our Sites or App, or by sending you an email (if we have your email). If permitted by law, users are bound by any changes to this Privacy Policy when they use the Services after such changes have been first posted.