Beintoo General Privacy Policy
(version 1.0 dated 16/04/2018)

Dear Visitor (hereinafter, “you” or the ‘”user“),

This page is owned by the company Beintoo S.p.a. having its registered office in Corso di Porta Romana 68, 20122, Milano (Italia), VAT No. and Fiscal Code No. 07295690965, registered with the Company Register of Milan under No. MI-1949117 (hereinafter, “Beintoo” or “We” or the “Company“).

This privacy policy (“Privacy Policy”) applies to Beintoo and offers a general overview on how we collect, use, share, and secure the personal information you provide, as well as your choices regarding use, access, and correction of your personal information.

Our Company carries on the activity of mobile marketing and advertising (collectively, our “Services”) as a mobile data company. As set forth below, this Privacy Policy applies to activities relating to your use of our website located at www.beintoo.com and all of our other websites and platforms to which this Privacy Policy is posted (collectively, the “Beintoo Website”), as well as to end users of third-party mobile applications (“Apps”) that use our Services.

We also collect analytics and other information using certain technologies such as cookies, pixels, and similar tracking technologies, as described more fully in the “Cookies Policy” section of Beintoo Website.

Users of the Beintoo Website

Beintoo provides this Privacy Policy pursuant to Article 13 of the Legislative Decree No. 196/2003 (the “Privacy Code”), in its capacity as a data controller in relation to the personal information of users visiting the Beintoo Website.

Beintoo takes the utmost account to the privacy rights and the protection of its Users’ personal information. Users may contact Beintoo for any information in relation to this Privacy Policy at any time using the contact information specified below.

Information We Collect.  

In general, you may visit the Beintoo Website without telling us who you are or revealing any information about yourself. As described in this section, you may enter personal information via the Website, which we will use solely for the purposes described.

In addition, we may automatically collect personal data (collectively, “Analytics”) from your desktop computer, laptop, mobile phone, tablet, or other consumer electronic device that you use to access the Beintoo Website (each, a “Device”). Analytics may include technical information about your Device (such as the Device type, operating system, settings and system configurations, IP address, Device ID and other unique Device identifiers, and mobile network information) and your activity using the Website (such as data about the webpages you access, traffic to and from websites, the dates and times associated with transactions, web log data, and other event information, including crashes and system activity). We may use Analytics for research and internal purposes, such as to improve the Website so that it is more useful and accessible to you and to provide relevant advertising to you. Analytics may be correlated with other personal data referring to you but not shared with any third parties.

Information Collected via Our “Contact Us” Page.  When you contact us, create a customer account, or submit an inquiry via the Website, we may collect personal information from you, which may include your name, address, email address, and phone number.

When you use the “Contact Us” page of our Website, your personal information will be processed by Beintoo for the sole purpose of replying to your queries, as specified in the “Privacy Policy Contacts”. No other processing will be conducted on your personal information. Processing will be carried out by manual and IT instruments, applying logics strictly connected to the purposes and, in any case, so that the safety and confidentiality of the relevant data is guaranteed.

Use and Sharing of Information Collected on the Beintoo Website.  Beintoo’s employees and/or workers appointed to manage personal information may become aware of any Users’ personal information, in order to send you any service information, and reply to your questions and concerns. Such subjects, who are formally appointed by Beintoo as “persons in charge for the processing”, will act as service providers that process the relevant User’s data exclusively for the purposes specified under this Privacy Policy and in compliance with the provisions of the Privacy Code.

The third party service providers which may process personal data pursuant to Beintoo’s instructions as “data processors” may include, but are not limited to, providers of logistics and IT services functional for the Website’s operations, outsourcing or cloud computing services providers, professionals and advisors, and companies entrusted with the sending of e-mails on our behalf. Any users have the right to obtain a list of the data processors (if any) appointed by Beintoo upon a specific request made to Beintoo via any of the contact methods noted below.

In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet law enforcement requirements. We may also disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

Access to Information Collected on the Beintoo Website.  Pursuant to Article 7 of the Privacy Code, Beintoo hereby informs that any user has the right to request (i) the source of the personal information; (ii) the purposes and methods of the processing; (iii) the logic applied to the processing, if the latter is carried out with the help of electronic means; (iv) the identification data concerning data controller and data processors; (v) the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated data processor(s) or person(s) in charge of the processing.

Furthermore, data subjects have the right to obtain: a) updating, rectification or, where interested therein, integration of the data; b) erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed; c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.

Users have the right to object, in whole or in part: a) on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection; b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.

Users may exercise such rights by contacting Beintoo by the methods listed in the Contact Us section below.

 

Tracking Technologies.  Beintoo and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on Beintoo Website or service. More information on this may be found in our Cookies Policy.

Choice We partner with third party companies to display advertising on our properties or to manage our advertising on other sites. Our third party partner may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising click here, or if located in the European Union click here. Please note you will continue to receive generic ads. More information on cookies and other tracking technologies is listed in our Privacy Choices and Opt-Out Rights section and Cookies Policy below.

Security and Retention.  The security of your personal information is of paramount importance to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at privacy-group@beintoo.com.

We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.

Changes to This Privacy Policy.  We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Us.  You may contact Beintoo to discuss this Privacy Policy or related questions at any time via the following methods: (i) sending a registered letter with return receipt to the registered office of Beintoo, (ii) sending an e-mail message to privacy-group@beintoo.com, or (iii) sending a fax to the following number: +390294751146.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

End Users of Apps Using Beintoo Services

Beintoo is a mobile data company that focuses on the collection and use of precise location data, to help advertisers provide more relevant offers to mobile application users. Beintoo receives this location information from a server-to- server transfer and SDK integration with mobile application partners. This location information generally includes lat./long. data, i.e., GPS-level data, and/or WiFi data (if feasible) associated with a mobile advertising ID, such as an IDFA or an Android Advertising ID (GAID).

We also collect personal data from third-party devices present at certain third-party locations, such as stores, shopping malls, stadiums, bars, restaurants, and other points of interest. Such devices may use Wi-Fi, near field communication (NFC), or Bluetooth low-energy (BLE) beacon technology to transmit signals about the location of your Device to us.

We use the data we collect to make inferences about what types of activities users tend to spend time doing. For instance, we may notice a particular Device frequently at locations associated with car buying (e.g., a dealership), apparel shopping (e.g., a mall or outlet), eating out (e.g., restaurants) or movie-going (e.g., movie theatres). We use this information to categorize Device users into “interest segments” – which advertisers can use to send ads when those users appear on mobile ad platforms they work with.

We also use some of the information we collect (including location information or mobile advertising IDs) to help advertisers analyze aggregate ad performance – such as by measuring whether or how Devices that saw a particular ad tended to engage with a particular product. In addition, we sometimes use any or all of the above information to help advertisers better understand their customers or their marketing, such as for market research, customer analytics, or analytics of traffic patterns.

Pixel Data: As to data collected through pixels or web beacons (“Pixel Data”), we use such data to directly perform or allow our partners to perform aggregated “attribution” analysis, which can help marketers and their service providers understand which users have been exposed to which ad campaigns. This may help marketers analyze and optimize their ad campaigns, for instance, on an aggregated basis. This data may likewise be measured or matched against aggregate location data in order to provide a “match rate” for an attribution study as to devices that have been detected at a given location– to provide similar services and analysis for marketers as those described above. For instance, if numerous Devices that were sent an ad or offer for “XYZ Coffee” on Tuesday then went to a XYZ Coffee on Wednesday or Thursday, an advertiser might conclude that the ad campaign was successful.

We refer to all of the above services as the “Services.”

When you have accessed or used an App that uses the Services, the publishers of such App may allow us to automatically collect data about your Device and your activity and interaction with such App, which does not directly identify you and which may include:

  • IP address
  • Geolocation and proximity of your Device if location services are enabled on your Device
  • Unique Device identifiers for advertising (Google Advertiser ID or IDFA) and/or a pixel identifier
  • Event information about your Device, such as crashes, system activity, and hardware settings
  • System configuration information
  • Time and date information
  • Other personal data that publishers share with us

Dwell time near points of interest, as determined through beacon, Wi-Fi, and other signals as discussed below and our proprietary systems. We may use these data to provide and improve the Services, including, but not limited to, the following purposes:

  • To develop and use predictive models to predict end users’ potential future behavior and interests on a per-Device basis and across Devices
  • To provide targeted advertising to end users, including through the creation of user interest categories
  • To attribute end users’ visits to stores or other specific points of interest for advertising campaigns
  • To help publishers enhance their user profiles

We may share the data above, and our analytics related thereto, to provide and improve the Services and as follows:

  • With publishers for their advertising, analytics, or other purposes
  • With advertisers so they may provide targeted content and advertising to you on websites and mobile applications
  • With other third parties, such as demand-side platforms, advertising platforms, data management platforms, advertising agency trading desks, proximity solution providers, advertising technology providers, so they may provide targeted content and advertising to you on third-party websites, mobile applications, and other advertising mediums, and so that they may measure ad performance through the types of ad “attribution” we discuss above.
  • As otherwise set forth in this Privacy Policy

Sometimes, we may provide information (such as IP address, but excluding precise lat/long coordinates) to third party platforms, connected to interest segments, to help advertisers identify common users across different Devices or browsers – for instance, to identify a common set of users on both mobile Devices or tablets, as well as the web.

Privacy Choices and Opt-Out Rights.  When we collect location information (generally speaking, lat/long coordinates greater than two decimal places) from mobile App partners, we endeavor to work with partners that provide disclosures to their own users regarding the use of mobile data for interest-based advertising purposes, and regarding consumer opt out rights.

You may manage certain collection and sharing of information in connection with the Beintoo Website and our Services as follows:

  • You may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser. This is described more fully in our Cookies Policy below.
  • You may limit the disclosure of certain personal data by your mobile Device to us and publishers by adjusting the settings on your mobile Device. For iOS mobile Devices, go to “Settings” from your Device’s home screen; scroll down to “Privacy”; select “Advertising”; and turn on “Limit Ad Tracking.” For Android mobile Devices, go to “Google Settings” on your Device; select “Ads”; and check the box labeled “Opt Out of Interest-Based Ads.” We honor these “limit” or “opt out” instructions or “flags” by removing recognized Devices from our cross-app advertising or ad delivery and reporting solutions, on a going forward basis. (We may continue to use data from these Devices for other purposes, such as market research and aggregated customer analytics, but we will not use this information for interest-based advertising purposes.)
  • While we do not currently have a web-based solution, you may opt out of certain advertisers’ cookies and browser-enabled, interest-based advertising at the Network Advertising Initiative’s website here and the Digital Advertising Alliance’s website here. Please note that these opt outs apply to interest-based advertising by participating advertisers. You may still receive other types of online advertising from participating advertisers, and the websites you visit may still collect data for other purposes. In addition, the opt-out choices you select are stored in opt-out cookies only in the browser that you use to visit the opt-out websites, so you should separately set your preferences for other browsers or Devices you may use. Deleting browser cookies can remove your opt-out preferences, so you should visit these opt-out websites periodically to review your preferences or update your preferences to apply to new participating advertisers.
  • Publishers and advertisers may also provide ways for you to opt out from or limit their collection of data from and about you. Please refer to the privacy policies for the Apps to learn more about the privacy practices of publishers and advertisers. Please note, however, that we are not responsible for the privacy practices of publishers, advertisers, and other third parties.
  • You may opt not to receive promotional emails from us by contacting us as indicated in this Privacy Policy or by following the “unsubscribe” instructions in any promotional email you receive from us, or by contacting us at privacy-group@beintoo.com. Please note, however, that we may still send you non-promotional, transactional or service-related emails about your relationship with us.

Cookies Policy

In addition to the information presented in our Privacy Policy, we are a third party in relation to the website and/or the mobile version of the website and/or the app where you are coming from (the
Website of Origin”)

Since our services use cookies for several purposes, we hereby aim at explaining to you what cookies are and how they are used.

Certain cookies (the so called proprium cookies or first part cookies) are conveyed and controlled by us directly. The Company collects and processes your personal data by means of these cookies. We hereby explain to you how we collect such data, for which purposes and what your rights are, also pursuant to Article 13 of the Legislative Decree No. 196 of 30 June 2003 (the “Privacy Code”).

Other cookies (i.e. third party cookies) are however conveyed and controlled by third parties. In this policy (“Cookies Policy”) you will find links to the information published by these third parties, which we suggest you to read carefully.

What cookies are and what they are for.  Cookies are small text files that the websites visited by a user send directly to its terminal (usually, to the browser) for storage, where they are then recognized by the same website during the same user’s subsequent visits (the so called proprium first part cookies). During the web surfing of a website, a user may also receive on its terminal cookies of other websites or of other web servers (the so called third parties cookies); this happens because there may be elements on the visited website, such as images, maps, sounds, links to specific web pages of other domains that are on servers other than the server on which the requested page is placed. In other words, such cookies are set up on a website other than the one that is currently visited.

Cookies may have a duration limited to a single session of navigation on the browser (the so called session cookies), and, in such event, they deactivate automatically once the browser is closed by the user; or may have a predetermined duration and, in such event, they will remain memorized and active on your hard disk until the expiry date, thus continuing collecting information during different sessions of navigation on the browser (the so called permanent cookies).

Cookies are used for several purposes. Certain cookies are necessary in order to allow you to surf the website and benefit of its functionalities (the so called technical cookies). Other cookies are used in order to obtain statistical information, whether in aggregate or not, about the number of users accessing the website and how the website is used (the so called monitoring cookies or analytics). In addition, other cookies are used in order to track your consumer profile and display tailored advertisings that may be of interest for you, according to your preferences and your consumer habits (the so called profiling cookies).

Further details about these varying categories of cookies are described below. Please discover how they work and for what they are used, and choose freely if you want to consent to their use or prevent the same.

Monitoring or “analytics” cookies.  The analytics are used in order to collect statistical information, whether on aggregate or not, on the number of users accessing a service.

The analytics cookies are third parties cookies, since they are not conveyed directly by us they are not installed directly by the Company but by third parties subjects.

The following third parties analytics are installed with your prior consent, since the same are not anonymised, given that third parties can access to analytics disaggregated data at the IP address level (in other words, using these cookies, third parties could theoretically go back to your identity by means of the IP address):

Cookie’s denomination Cookie’s category Link to the policy / opt-out instructions
Google Analytics –third-party analytics cookies

– lasting

https://www.google.com/analytics/learn/privacy.html?hl=it
www.google.it/policies/privacy/partners/

You are clearly free to block the installation of analytics cookies in any moment whatsoever and this will not compromise in any manner whatsoever the possibility to visit the Website of Origin and benefit of its contents. Please read carefully the third parties cookies policies, following the links specified in the above table, in order to know how to do it.

Profiling cookies and/or other identifiers (both referred to as “Cookies”). The profiling cookies are used to create a user’s profile, based on the preferences and likings showed by you during the navigation on Internet and to make you display advertisings consistent with your profile. This is done to show you advertising that is more tailored and relevant to your interests.

In order to disable these profiling cookies, either change your browser settings (see the paragraph (1) below) or read the section entitled “Information on Opting Out on Mobile Devices” found on the website https://www.networkadvertising.org/mobile-choice, and the “What Are My Options” section on the website https://www.networkadvertising.org/understanding-online-advertising/what-are-my-options, which assist users in exercising their consumer choices on various devices.

Your prior consent is requested in order to install such cookies, as provided pursuant the current privacy law. For such a reason, when you access the Website of Origin a specific banner is displayed, informing you that (i) profiling cookies are used on the Website of Origin and that (ii) closing the banner, surfing on the home page or clicking whatever element on the home page outside the banner, You are giving your consent to the use of cookies. In the event that you express your consent to the use of cookies in this way, We will track your consent by means of a specific technical cookie. In this way, we will avoid you displaying the cookies banner during your following visits of the Website of Origin. Please take into account that, in the event that you remove from your browser such technical cookie with the modalities set forth under the following paragraph (1) below, the track of your consent would be lost and, therefore, the cookies banner will be displayed again during your following visit to the Website of Origin.

You are clearly free to block the installation of profiling cookies in any moment whatsoever and this will not compromise in any manner whatsoever the possibility to visit the Website of Origin and benefit of its contents.

Profiling systems, both cookie and Device data, will be installed by the Company itself (“first-party profiling cookies”). These cookies are permanent and they expire within 12 months. There follows below a list of the first-party profiling cookies that We utilize:

Tracking name Tracking category
trk.beintoo.net – first party profiling tracking

– lasting

– device identifiers

 

The greater part of the profiling cookies are installed by third parties that act as autonomous data controllers (third parties cookies). The third parties profiling cookies used by our Service are the specified in the following table, together with the link to the policies created by their developer:

Source Tracking category Link to the policy / opt-out instructions
TheTradeDesk – third party profiling tracking

– lasting

https://www.thetradedesk.com/general/privacy-policy
Adform – third party profiling tracking

– lasting

http://site.adform.com/privacy-policy/en/
Criteo – third party profiling tracking

– lasting

http://www.criteo.com/it/privacy/
Cuebiq – third party profiling system

– lasting

http://www.cuebiq.com/privacypolicy
Facebook – third party profiling tracking
– lasting
https://www.facebook.com/policies/cookies/
Google AdWords – third party profiling tracking
– lasting
https://policies.google.com/technologies/ads?hl=it
LinkedIn – third party profiling tracking
– lasting
https://www.linkedin.com/legal/cookie-policy

How to manage the cookies and oppose to their use. There are several options to manage, disable and remove the cookies.

(1) Modify your browser settings

Please follow the instructions provided by your browser’s producer to discover how to manage, disable or remove all the cookies (technical, analytics and profiling):

(2) Use our interactive instruments

In order to disable the third parties cookies, please see the privacy policies of those third parties installing analytics cookies (see paragraph B above) or profiling cookies (see paragraph C above) in order to know the other instruments available to you for managing, disabling and removing cookies and, more in general, to oppose to their use. Please be reminded that, by disabling third parties cookies, (i) you are opposing to their use not only on the Website of Origin, but on all the Internet websites on which such cookies are used and (ii) the possibility to surf on the Website of Origin and use its functionalities will not be jeopardised in any manner whatsoever. When you disable the third parties cookies, you will however display the banner on the cookies on the Website of Origin’s home page; but, in such event, closing the banner and surfing the home page or clicking an element whatsoever outside the banner, you will not receive any third party cookie you have duly disabled.

(3) Use the Internet website www.youronlinechoices.com/uk/  

Your Online Choices is an Internet website managed by the non-profit organisation European Interactive Digital Advertising Alliance (EDAA), the English version of the same is available at the
address http://www.youronlinechoices.com/uk/, providing information on the behavioural advertisings based on profiling cookies (http://www.youronlinechoices.com/uk/about-behavioural-advertising) and allow the Internet users to oppose easily (opt-out) to the installation of the main profiling cookies installed by the marketing operators and used on Internet websites
(http://www.youronlinechoices.com/uk/your-ad-choices). Before using this instrument, we hereby recommend you to read carefully the general terms and conditions of the site Your Online Choices (http://www.youronlinechoices.com/uk/terms-conditions), the frequently asked questions (FAQ) (http://www.youronlinechoices.com/uk/faqs) and the users’ guide (http://www.youronlinechoices.com/uk/download-guide).

Please use Your Online Choices consciously. Indeed, notwithstanding that many of the most important marketing companies using cookies are members of the same, certain third parties installing cookies through the Website could not be members of Your Online Choices. Therefore, the use of Your Online Choices does not guarantee that third parties cookies will be received surfing on the Website. Please be remained that, removing all the cookies from the browser, also the technical cookies released by Your Online Choices in order to remind your choices could be removed, thus reactivating third parties cookies.

 

4. Other information

As highlighted under the preamble of this policy, the Company collects and processes certain personal information by means of the cookies conveyed directly on the Website (first part cookies). The Company acts as data controller of such data, in compliance with the provisions of the Privacy Code. Please note that we will process your data with electronic instruments only, in a much automatized manner and without any human intermediation. Therefore, our employees and co-workers will never access the content of your personal information obtained by means of cookies.

Certain employees of ours and co-workers, appointed by us as data controllers, could make maintenance operations on IT systems that host your data, without the possibility to access their
actual contents. The personal data could be memorised on servers managed by third parties (for example, providers of IT systems) or may be managed by online marketing specialised subjects, acting as external data controllers on the basis of a specific written appointment by the Company. We hereby inform you that, complying with the requirements and the guarantees provided under the law, your data could be transferred to Countries outside the European Economic Union that could not guarantee a level of privacy and personal data protection equal to the level of protection guaranteed by the Italian and European privacy laws. Your personal data will not be transferred to third parties data processors, nor will be disseminated.

 

5. Your rights

Pursuant to Article 7 of the Legislative Decree 30 June 2003, No. 196, you have the right to obtain confirmation of the existence or not of personal data pertaining to you and to know its content and source, verify the correctness of the same or require the integration, the update or the rectification of the same (Article 7 of Legislative Decree No. 196/2003). You have also the right to require the cancellation, anonymisation or the block of data processed in breach of the law, as well as to oppose in any event, for legitimate reasons, to their processing. In the end, you have the right to obtain a list of the external data controllers appointed by the Company. In order to exercise your rights, or to obtain any other information or clarification in relation to this policy, please contact the Company by means of registered letter with return receipt (to the following address Corso di Porta Romana, 68 – Milan 20122– Italy), by e-mail (to the following address info@beintoo.com) or by fax (to the following No. +39 02 97687959).