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,"
in this document,
We believe in complete transparency to our
consumers on how their information and data is collected and used. This
Identifiable Information"), which 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 in this Privacy
Policy and you hereby consent that we will collect, use, and share
Your use of GeoSpark's Services is at all times subject to the GeoSpark
Policy without defining them have the definitions given to them in The
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 "Clients."
disclose information about the end users, referred to by the term
, of third-party mobile applications and Clients who
use our Services.
gathered by us when you access or use our Services, but not to the
practices of companies which are neither owned nor controlled by us, or
means all types of PII (Personally Identifiable
Information), and "processing"
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
If you are a resident of the European Union, referred to as "EU"
United Kingdom, Lichtenstein, Norway, or Iceland, you may have
additional rights under the EU General Data Protection Regulation,
referred to as the "GDPR"
, 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 email@example.com
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
Precise location (e.g., GPS-level) data, such as latitude,
longitude, altitude, speed, heading
Mobile advertising identifiers (e.g., Apple IDFAs and Android
- IP addresses
Device information (e.g., device make, device model, and operating
- Time zone information
- Privacy preferences
We may share the SDK Information with third parties in the following
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
products, services and applications of our Clients, referred to as
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 to as
The Client Information may include, the
following types of data without limitation, some of which may be
- 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 us to uniquely
identify it. Where required by applicable law, we obtain your consent
to accept our cookies, you may not be able to utilize all the features
of our products and services. If you are a resident of the EU or other
our sites, then you will have 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
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/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 Amplitude, referred to as
similar information gathering 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
- 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 below.
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.
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 to perform
and support our marketing and analytics functions as described in this
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 provide us with services
These parties may include:
- 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
Comply with applicable law or respond to valid legal process,
including from law enforcement or other government agencies
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
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
and to comply with our legal obligations, resolve disputes, and enforce
our Terms and other agreements.
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
third parties and websites, and the industry tools that we have
applies to the GeoSpark Website and Services.
12. EU Residents
If you are a resident of the European Union ( "EU"
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
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
What Personal Data Do We Collect From You?
Please see the Section
"Information We Collect From You"
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 Personal Data.
How Do We Use Your Personal Data?
Please refer to the Section
"With Whom We Share Your Personal Data"
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?
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 at
. 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 Personal Data.
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
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
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
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 means.
14. Contacting Us
to request that we delete any SDK Information about you that is
collected or stored through the Services, please contact us at
time to time. When we do, we will revise the "last updated" date given
frequently and to remain informed of any changes. The then-current
agree that your continued use of the Services after such changes have
been published to will constitute your acceptance of the revised Privacy
Oct 31, 2018