GeoSpark, Inc. located at 2035 Sunset Lake Road, Suite B-2, Newark, New Castle, Delaware - 19702, henceforth referred to
by the terms
"GeoSpark," "we," "us,"
We believe in complete transparency to our consumers on how their information and data is collected
comprises data that we obtain through our Services, but not to the practices of companies which are neither owned nor
controlled by us, or people who are not managed by us.
On using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined
Policy without defining them have the definitions given to them in The Terms.
GeoSpark offers its Services to application developers. GeoSpark's Services enable developers to collect, analyze,
and act on location data obtained from individual devices. All of GeoSpark's developers and partners are referred to
collectively as our
to by the term
, of third-party mobile applications and Clients who use our Services.
but not to the practices of companies which are neither owned nor controlled by us, or people who are not managed by
means all types of PII (Personally Identifiable Information), and
means all actions that can be executed concerning the personal which includes collection, use, storage
Various forms of Personal Data are collected from our users which is explained briefly below.
This Personal Data is used internally in regard to our Services, so as to personalize, provide, and improve our services,
to enable you to set up a user account and profile, to contact you as well as enable other users to contact you, to
fulfill your requirements for specific products and services, and to analyze your usage of the Services. We may also
share specific Personal Data with third parties, but limited to the description below.
If you are a resident of the European Union, referred to as
, United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data
Protection Regulation, referred to as the
, pertaining to your Personal Data, as mentioned below. GeoSpark may be the controller of your Personal Data
processed with regard to the Services. If you have any queries regarding this section or if any of the following is
applicable to you, please contact us at
. We may also process Personal Data of end users of our customers with regards to our provision
of services to customers, in which case we are the processor of Personal Data. In the case of us being the processor
of your Personal Data and not the controller, you are to contact the controller party in the first instance to address
your rights in regards to such data.
2. End User Information
The information that is collected by us from End Users automatically via our Services on behalf of our Clients is
referred to as
SDK Information shall be used only to provide the Services to our Clients, and for no other
purpose. Access to your SDK Information will not be provided by us to any other third party without your consent. The
SDK Information may include, without limitation, the following types of data, some of which may be Personal Data:
- Precise location (e.g., GPS-level) data, such as latitude, longitude, altitude, speed, heading
- Mobile advertising identifiers (e.g., Apple IDFAs and Android advertising IDs)
- IP addresses
- Device information (e.g., device make, device model, and operating system version)
- Time zone information
- Privacy preferences
We may share the SDK Information with third parties in the following ways:
- We share the SDK Information with our Clients in order to provide our Services to them.
- We may share the SDK Information with the End User that is the subject of the SDK Information, upon Client's request.
- We share the SDK Information with our integration partners on Client's behalf and request in order to provide the
Services to our Clients.
We do not hold responsibility for teh SDK Information being handled by our Clients. Our Clients
have their own policies regarding the collection, use and disclosure of your Personal Data. For information on how
a particular Client handles your personal information, we encourage you to read the Client's privacy statement. Our
use of SDK Information provided by our Clients with regard to our Services is subject to the written agreement between
us and the Client.
3. Information We Collect From You
If you are a Client, your Personal Data will be collected by us when you sign up and register for the Services, referred
The Client Information may include, the following types of data without limitation, some
of which may be Personal Data:
- First and last name
- Email address
- Phone number
- Company name
- Payment information
- IP address
- Web browser information
- Page view statistics
- Browsing history
- Usage information
- Transaction information (e.g., transaction amount, date and time such transaction occurred)
- Cookies and other tracking technologies (e.g. web beacons, pixel tags, SDKs, etc.)
- Log data (e.g., access times, hardware and software information)
On visiting our site, we will send you a cookie, which is a small file stored on your computer that allows
our cookies, you may not be able to utilize all the features of our products and services. If you are a resident of
an opportunity to manage your cookie preferences on such sites; except that certain cookies are essential to enable
core site functionality, and you cannot choose to disable those cookies. Through cookies that we place on your browser
or device, we may collect information about your online activity after you leave our Services. Just like any other
usage information we collect, this information allows us to improve the Services and customize your online experience,
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/or across different websites.
Our Services do 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 Services and after you leave our Services.
Third Party Analytics.
Our Services may use third party analytics tools, such as Segment, Google Analytics, and
technologies to collect standard internet log information and usage information. The information generated is used
to collect and compile statistical reports on user activity. The Analytics Providers collects information such as how
often users visit a website, what pages they visit when they do so, and what other websites they visited prior to coming
to a website. We use the information obtained from these applications only to improve our Services, our product and
service offerings. The information generated about your use of our Services will be transferred and saved to the vendor's
server in the United States.
4. How We Use Your Personal Data
Client information is processed in order to operate, improve, understand and personalize our Services. For example,
we use Client Information to:
- Create and manage Client profiles
- Communicate with you about the Services
- Process orders
- Contact you about Service announcements, updates or offers
- Provide support and assistance for the Services
- Personalize website content and communications based on your preferences
- Meet contract or legal obligations
- Respond to Client inquiries
- Fulfill Client requests
- Comply with our legal or contractual obligations
- Resolve disputes
- Protect against or deter fraudulent, illegal or harmful actions
- Enforce our Terms
We will only process your Client Information if we have a lawful basis for doing so. Lawful bases for processing include
consent, contractual necessity and our "legitimate interests" or the legitimate interest of others, as further described
We process the categories of Client Information mentioned below as a matter of "contractual
necessity", meaning that we need to process the data to perform under our Terms of Service with you, which enables
us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Client
Information will result in your inability to use some or all portions of the Services that require such data.
- First and last name
- Email address
- Payment information
- IP addresses
We process the following categories of Client Information when we believe it furthers the
legitimate interest of us or third parties.
- Email address
- Payment information
- IP address
Examples of these legitimate interests include:
- Operation and improvement of our business, products and services
- Marketing of our products and services
- Provision of customer support
- Protection from fraud or security threats
- Compliance with legal obligations
- Completion of corporate transactions
In certain cases, we process Personal Data based on the consent you expressly grant to us at the time
we collect such data, for example marketing and promotional emails. When we process Personal Data based on your consent,
it will be expressly indicated to you at the point and time of collection.
Other Processing Grounds:
From time to time we may also need to process Personal Data to comply with a legal obligation,
if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried
out in the public interest.
Information that's no longer personally identifiable.
We may anonymize your Personal Data so that you are not individually
identified, and provide that information to our partners. We may also provide aggregate usage information to our partners,
who may use such information to understand how often and in what ways people use our Services, so that they, too, can
provide you with an optimal online experience. However, we never disclose aggregate usage information to a partner
in a manner that would identify you personally, as an individual. For example, we currently use Analytics Providers
5. With Whom We Share Your Personal Data
We may share Client Information with vendors, third party service providers and agents who work on our behalf and
- Payment processors
- Analytics service providers
- Email marketing and management service providers
- Customer support providers
- Hosting service providers
We also share Client Information when necessary to complete a transaction initiated or authorized by you or provide you with
a product or service you have requested. In addition to those set forth above, these parties also include:
- Third party business partners who you access through the Services
- Other parties authorized by you
We also share information with third parties when you have given us consent to do so (as indicated at the point such information
is collected). We also share Personal Data when we believe it is necessary to:
- Comply with applicable law or respond to valid legal process, including from law enforcement or other government
- Protect us, our business or our users, for example to enforce our terms of service, prevent spam or other unwanted
communications and investigate or protect against fraud
- Maintain the security of our products and services
- Last, we share Personal Data with our affiliates or other members of our corporate family.
Furthermore, if we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover,
if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information
would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with
the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us
or our assets may continue to use your Personal Data as set forth in this policy.
6. Consumer Control and Opt Out Options
End Users can opt out of sharing their location by turning off location services. On iOS, go to Settings > Privacy
> Location Services. On Android, go to Settings > Location. When you opt out of location sharing, the Services no longer
collect any location based-data from your device. End Users can also opt out of sharing their mobile advertising identifiers.
On iOS, go to Settings > Privacy > Advertising and turn on "Limit Ad Tracking." On Android, go to Settings > Google
> Ads and turn on "Opt Out of Ads Personalization." If End Users opt out from sharing the aforementioned data with
us, please note that the Services provided may be affected and some features may be unavailable. Please note that the
instructions above may change.
7. Notice of EU-U.S. and Swiss-U.S. Privacy Shield Participation
GeoSpark has certified to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks set forth by the U.S. Department of
Commerce regarding the collection and use of Personal Data transferred from the EU and Switzerland. For more information
about the Privacy Shield Program, and to view GeoSpark's certification, please visit
GeoSpark is committed to the Privacy Shield Principles of (1) notice, (2) consent, (3) accountability for onward transfer,
(4) security, (5) data integrity and purpose limitation, (6) access and (7) recourse, enforcement and liability with
respect to all Personal Data received from within the EU in reliance on the Privacy Shield. The Privacy Shield Principles
require that we remain potentially liable if any third party processing Personal Data on our behalf fails to comply
with these Privacy Shield Principles (except to the extent we are not responsible for the event giving rise to any
alleged damage). GeoSpark's compliance with the Privacy Shield is subject to the investigatory and enforcement powers
of the U.S. Federal Trade Commission.
The Services are hosted and operated in the United States ("U.S.") through GeoSpark and its service providers, and
laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal
Data about you and End Users, regardless of whether provided by you or obtained from a third-party, is being provided
to GeoSpark in the U.S. and will be hosted on U.S. servers, and you authorize GeoSpark to transfer, store and process
your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data
to the U.S. pursuant to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks.
8. Data Access and Retention
Generally speaking, we retain the SDK Information for as long as necessary to achieve our objectives as detailed in
You can contact us at
if you have any other questions about access to, or correction or deletion of, your Personal
Data or SDK Information.
California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled
to ask us for a notice identifying the categories of personal customer information which we share with our affiliates
and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties.
If you are a California resident and would like a copy of this notice, please submit a written request to the following
address: GeoSpark Labs, Inc., 20 Jay Street, Suite 704, Brooklyn, NY 11201
9. Personal Data of Children
As noted in the Terms, we do not knowingly collect or solicit personal information from anyone under the age of 13.
Please do not send any personal information about any children under the age of 13 to us. If we learn that we have
collected personal information from a child under age 13, we will delete that information as quickly as possible. If
you believe that a child under 13 may have provided us personal information, please contact us at
10. Data Security
We have administrative, technical, and physical safeguards in place in our physical facilities and in our computer
systems, databases, and communications networks that are intended to protect information contained within our systems
(including SDK Information) against unauthorized loss, misuse, or alteration. However, no method of electronic transmission
or storage is 100% secure. Therefore, we cannot guarantee absolute security of your personal information and other
information and data.
11. Third-Party Websites and Applications
We are not responsible for the privacy practices or disclosures of our Clients or any other websites and applications
that use our Services. Likewise, when you access the GeoSpark Website, you may be directed to other websites that are
also beyond our control. We encourage you to read the applicable privacy policies and terms and conditions of such
however, only applies to the GeoSpark Website and Services.
12. EU Residents
If you are a resident of the European Union (
), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data
Protection Regulation (the
) with respect to your Personal Data, as outlined below. For this section, we use the terms "Personal Data"
and "processing" as they are defined in the GDPR, but "Personal Data" generally means information that can be used
to individually identify a person, and "processing" generally covers actions that can be performed in connection with
data such as collection, use, storage and disclosure. Company will be the controller of your Personal Data processed
in connection with the Services. If there are any conflicts between this section and any other provision of this Privacy
Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict.
If you have any questions about this section or whether any of the following applies to you, please contact us at
. For purposes of this section only, Personal Data shall be limited to Client Information.
What Personal Data Do We Collect From You?
Please see the Section
"Information We Collect From You"
above for details of the Personal Data we collect.
Information we collect directly from you: We receive Personal Data directly from you when you provide us with such
How Do We Use Your Personal Data?
Please refer to the Section
"With Whom We Share Your Personal Data"
above for details on how we use and process your Personal Data.
How Long Do We Retain Your Personal Data?
We retain Personal Data about you for as long as you have an open account
with us or as otherwise necessary to provide you Services. In some cases we retain Personal Data for longer, if doing
so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted
or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated
form but not in a way that would identify you personally. We also may retain your information during the period of
time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations,
resolve disputes and enforce our agreements.
What Rights Do You Have Regarding Your Personal Data?
You have certain rights with respect to your Personal Data,
including those set forth below. For more information about these rights, or to submit a request, please contact us
. Please note that in some circumstances, we may not be able to fully comply with your request,
such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required
by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also
need to you to provide us with additional information, which may include Personal Data, if necessary to verify your
identity and the nature of your request.
13. Questions, Concerns, or Complaints
Access: You can request more information about the Personal Data we hold about you and request a copy of such
Personal Data. You can also access certain of your Personal Data by going into your account and going into the
account settings and preferences tab and adjust your preferences and see our Personal Data.
Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you
can request that we correct or supplement such data. You can correct some of this information directly by going
into your account and going into the account settings and preferences tab and adjust your preferences and see our
Erasure: You can request that we erase some or all of your Personal Data from our systems.
Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time
of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that
if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or
disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some
or all of our Services.
Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request
that we transmit the data to another controller where technically feasible.
Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal
Data for certain purposes.
Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
Right to File Complaint: You have the right to lodge a complaint about Company's practices with respect to
your Personal Data with the supervisory authority of your country or EU Member State.
If you have any questions or concerns regarding privacy using the Services or about our Privacy Shield Certification,
please send us a detailed message to
, and we will make every attempt to resolve your concerns. If you do not receive timely acknowledgment
of your Privacy Shield-related complaint from us, or if we have not resolved your complaint, you may also resolve a
Privacy Shield-related complaint through our third-party dispute resolution provider located in the United States.
Under certain conditions, you may also be entitled to invoke binding arbitration for complaints not resolved by other
14. Contacting Us
about you that is collected or stored through the Services, please contact us at
your continued use of the Services after such changes have been published to will constitute your acceptance of the
Oct 31, 2018