SDK Privacy Policy (EN)
Your privacy in a nutshell
With this brief summary we want to inform you – in the spirit of GDPR – as transparently and clearly as possible about our activities, the data which we collect about you as a user of our technology, how we process those data, and how you can assert your rights in that regard.
Unless expressly agreed otherwise, the Client acknowledges that the language of this policy shall also be the language of communication in all commercial transactions with Accurat, or that the Client understands the language of these policies. The English language version of this policy shall be the only authentic one. Translations or documents drawn up in another language are provided as a mere convenience towards the Client.
What we do
Accurat develops technology (an SDK) which our customers integrate in their mobile applications. Our solution allows them to understand you better as a user so that they can offer you a better experience with the application.
Which data do we collect?
Our technology tracks your location several times a day and transmits those data to a data environment at Accurat. We never collect personal data such as your name, first name, email address, age, gender or other, nor do we receive those data from our customers.
Who do we share your data with?
Your data will only be shared with our customers whom you have given permission to use your data. This means that they – and no one else – can use your data. Some of our customers process your data through an intermediary. They, too, may only process your data for such purposes as you approved in their mobile application. This usually means personalized information and more relevant advertisements.
Your rights in a nutshell
As user of an application of our customers you may assert the following rights:
- Access to your data: all information which we collect about you may be accessed free of charge at any time. We will send you within one month a file containing all information we collected about you.
- Removal of your data: you may decide at any time that the data which we collect about you should be removed. In that case we will remove within one month all information which we collected about you.
- Access to and removal of your data takes place through our customers, i.e. the administrator of the mobile application whom you gave permission. As data processor, Accurat will assert your rights at their request within the appointed time limit (one month).
Questions?
You may send any questions you have by email to privacy@accurat.ai. We will make a point of answering your questions within five working days. Our DPO (Data Protection Officer) is Anja Lemmens, who can be reached at dpo@accurat.ai. If you want to know more about what our customers do with your data, we advise you to consult their privacy policy, which you can generally find on their application.
Extensive privacy policy
By using our solutions, the User agrees with the practices and guidelines set out in this Privacy Policy and consents to the collection, processing and sharing of his personal and non-personal Data with our Customers, for which he has granted express permission.
Accurat BV (“Accurat”, “We”, “Our”) is established at Leernsesteenweg 155, 9800 Deinze. This privacy policy (“PrivacyPolicy”) defines which data (“Data”) we collect through our solution(“SDK”) from the app users (“User”, “Users”, “His”), how we process those data, and with whom (“Customer”, “Customers”, “Their”) we share those data. The policy does not define how our Customers process theUser’s Data.
1. Activities of Accurat
Accurat offers its Customers an SDK. This technology allows Customers to collect Data about the Users through Their mobile applications and to share those Data with Accurat in order to acquire further insights(processing of Data) such as profiling, and to use those insights to improve Their services. This Privacy Policy explains how we collect, process and share the data of Users with our Customers. Although we do not collect personal information of Users, the Data which we collect may as a result of processing lead to the identification of a User. We make a distinction between personal and non-personal Data. As Processor, we collect, process and manage both forms of Data with due and proper care, and various measures are taken to protect those Data. If you wish to assert your rights as a User as defined below, theData Controller, our Customer, is primarily responsible. As Data Processor,Accurat will carry out your requests regarding your Rights within the legal time limit of 30 days.
2. What data are collected?
Accurat collects and processes the following Data ofUsers:
- Exact location (GPS signal data), such as latitude, longitude, altitude, speed, heading and accuracy of the location;
- “Mobile advertising identifiers” such as Apple IDFA for iOS devices and Android Advertising ID for Android devices;
- Name of the WiFi and mobile phone network of the User;
- Information about the User’s device (make, model and version of the OS);
- Time (time, hour, second, time zone);
- Privacy settings (consent to use the SDK).
The User Data that are collected and processed are only partially shared with our Customers for which the User has given his consent. These processed Data comprise the following profiling information:
- Shopping behaviour (category preference, store loyalty…)
- Mobility (car use, use of public transport, bicycle use…)
- Interests (sports, cultural interests…)
- Personal information (estimated household composition…)
The User’s location is never shared with the Customer.The SDK may be used to send an automated message based on the User’s location.This information is not shared with the Customer. Our services are not intendedfor children under the age of 13, and we do not knowingly collect information from children under the age of 13. Data is only collected by means of an explicit GDPR consent and by sharing location data using an OS-specific prompt.Children under 13 complying can only do so with the consent of their parents.
3. Transfer to third parties
We will not at any time sell or rent out your data toindividuals or companies that do not form part of Accurat. We use the servicesof external processors, and will always ensure that your data are handledconfidentially and used in a secure way. The external processors will always becontractually bound to Accurat. The processors will never be allowed to use your personal data on their own initiative. The User Data will be shared withthe following partners and by the following means:
- User Data will be shared in an aggregated manner over a web interface
- Processed User Data will be shared through the SDK with the application of our Customers when a User uses the application
- Processed User Data will be shared with the Processors (partners) of our Customers for which they have given their consent. They too may only use the processed User Data for the applications to which the User has consented.
- The service providers used by Accurat, such as hosting solutions (Google Cloud Services) or partners for data analysis, IT services or other similar services as requested by Accurat;
- In order to process the user data, we will allow our employees to access those data. Accurat guarantees a similar level of protection by enjoining contractual obligations on our staff members and appointees.
- A third party that may be entitled to the collected Data following a takeover or acquisition of Accurat.
The collected and processed Data will be retained fora three-year period necessary for the provision of our services and to comply with legal obligations as defined in this Privacy Policy. Once you have withdrawn your consent, all personal Data will be removed. Certain data may be retained in aggregated or depersonalized form, where it is impossible to identify the User. This Privacy Policy does not define how Customers or partners of Customers process the data. Accurat cannot be held responsible asProcessor for the use of User Data by Customers (as Controller) or partners (asProcessor) of our Customers. Customers each have their own privacy policy on how to handle user data. More information about the use of the processed UserData which we pass on to our Customers can be found in their respective privacy policies.
4. Legal obligations
In rare cases, Accurat may be required to pass on your data by virtue of a court order or in order to comply with other mandatory lawsor regulations.
5. How long will your data be retained?
The collected and processed data will be retained for as long as the partnership with our customers exists and has not been terminated by one of the parties. The personal data will be retained for another three years after the partnership with our customer has ended. Once you have withdrawn your consent, all personal Data will be removed. Certain data may be retained in aggregated or depersonalized form, where it is impossible to identify the User.
6. Minimum data processing
The user data which we collect are adequate and relevant for our purposes. We will restrict the collection of your data to the minimum required for the purposes for which we process the personal data.
7. Rights of the User
The User may at any time prevent his location being shared by disabling the location services through the operating system.
- In iOS that is Settings > Privacy > Location Settings.
- In Android: Settings > Location.
As soon as you opt out of those settings, no more UserData will be collected by the SDK. The User can prevent his “mobile advertising identifier” from being shared.
- In iOS this is done by activating “Restrict AdsTracking” in Settings > Privacy > Ads.
- In Android you can activate “Opt Out of Ads Personalization” in Settings > Google > Ads.
No more User Data will be collected from the moment the User prevents this identifier from being shared. Please note that the methods described above for setting those data may change. The rights provided for by GDPR legislation are the following:
- Access: the User may request access to the Data held by Accurat by contacting the persons indicated in the privacy policy of the Customers. Such access will be granted within one month.
- Rectification: the User may request rectification of the Data held by Accurat by contacting the persons indicated in the privacy policy of the Customers. Such rectification will take place within one month.
- Erasure: the User may request the erasure of the Data held by Accurat by contacting the persons indicated in the privacy policy of the Customers. Such erasure will take place within one month.
- Withdrawal of consent: the User may ask to withdraw the consent given to use the Data held by Accurat by contacting the persons indicated in the privacy policy of the Customers. Within one month, the collected and processed Data of a User will cease to be shared with the Customer.
- Data portability: the User may ask the Data held by Accurat to be transferred to a similar party by contacting the persons indicated in the privacy olicy of the Customers. Such transfer will take place within one month.
8. Data security
Accurat has taken technical as well as physical & administrative measures to secure the physical facilities, computer software, databases and network environments used with the utmost care. This should ensure that the User Data and other information are protected against loss, improper use or changes.Although no method can offer 100% guarantee, Accurat will make every effort to take every possible practicable measure. Accurat shall on no account be held liable for any direct or indirect damage resulting from erroneous or unlawful use of user data by third parties.
9. Modifications
Accurat reserves the right to modify this PrivacyPolicy at any time by posting those modifications on the Accurat website.
10. Questions, Concerns or Complaints
If a User or Customer has any questions about the SDK, our services or our Privacy Policy, contact us at privacy@accurat.ai. Complaints may be addressed to the supervisory authorities in case of any data breach or failure by Accurat to comply with the law.
AccuratBV
Leernsesteenweg 155, 9800 Deinze, België
CEO: Bart Muskala (bart@accurat.ai)
DPO: Anja Lemmens (dpo@accurat.ai)
Accurat complies with all the regulations imposed bythe Commission for the Protection of Privacy (CPP). If you disagree with the way Accurat.AI processes your data, you may contact the data protection authority:
Drukpersstraat 35, 1000 Brussels, België, Tel: 02/274 48 00, Fax: 02/274 48 35, contact@apd-gba.be
Or via The contact form