Privacy Policy

Orbital Insight, Inc. (“Orbital Insight,” “we,” “us,” and “our”) provides a geospatial analytics platform to help our customers analyze patterns and gain insight about various areas of interest around the world. Our Privacy Notice (“Privacy Notice”) is designed to help you understand how we collect, use and share personal information and to assist you in exercising the privacy rights available to you.

SCOPE

This Privacy Notice applies to personal information processed by us in our business, including on our platform, websites, and our related online and offline offerings (collectively, the “Services”).

PERSONAL INFORMATION WE COLLECT FROM CUSTOMERS AND WEBSITE VISITORS

Information Provided to Us

Account Creation. When you create a user account, we collect your name, email address, country of residence, employer/company name, and phone number.

Your Communications with Us. We collect personal information from you such as your name, company name, email address, phone number, location, or mailing address when you request information about our Services or otherwise communicate with us.

Customer Service and Support. If you call or otherwise interact with our customer service and support, we may collect the information you provide to our representatives. In addition, we may record telephone calls between you and our representatives for training and quality assurance purposes.

Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.

Interactive Features. We may offer interactive features such as collaboration tools, commenting functionalities, chat services, forums, and social media pages (e.g., Facebook, LinkedIn, Twitter, and Medium). Orbital Insight and other individuals who use our Services may collect the information you submit or make available through these interactive features. Any information you share on the public sections of these features will be considered “public” and is not subject to the privacy protections referenced herein.

Conferences, Trade Shows, and other Events. We may attend conferences, trade shows, and other events where we collect personal information from individuals who interact with or express an interest in Orbital Insight and/or the Services. If you provide us with any information at one of these events, we will use it for the purposes for which it was collected.

Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

Information Collected Automatically

Information Related to the Use of the Services. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, cookie and other unique identifiers, details about your browser, operating system or device, location information (including inferred location based off of your IP address), Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, information about how you interact with the Services, including the frequency and duration of your activities, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.

Cookies, Web Beacons, and Analytics. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your device that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services.

  • Cookies. Cookies are small text files placed in device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about engagement with the Services. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in emails to understand whether messages have been opened, acted on, or forwarded.

Analytics. We may use Google Analytics and other service providers to collect and process analytics information on our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the website by going to http://tools.google.com/dlpage/gaoptout.

Session Replay Providers. We use Hotjar for session replay analytics. Hotjar’s service allows us to record and replay an individual’s interaction with the Services. This helps us understand our user’s experience and how we can improve our Services.

For more information about Hotjar, please visit: https://www.hotjar.com/legal/policies/privacy. You can opt out of Hotjar’s processing of your information on our website by visiting: https://www.hotjar.com/legal/compliance/opt-out.

Information from Other Sources

We may obtain information about you from other sources, including through third party services and organizations. For example, if you access our Services through a third-party application, such as a third-party login service, we may collect information about you from that third-party that you have made available via your privacy settings.

HOW WE USE PERSONAL INFORMATION WE COLLECT FROM CUSTOMERS AND WEBSITE VISITORS

We use personal information for a variety of business purposes, including:

To Provide the Services or Information Requested, such as:

  • Fulfilling our contract with you or our customer;
  • Managing your information;
  • Responding to questions, comments, and other requests;
  • Providing access to certain areas, functionalities, and features of our Services; and
  • Answering requests for customer or technical support.

For Administrative Purposes, such as:

  • Pursuing legitimate interests, such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
  • Measuring interest and engagement in our Services;
  • Developing new products and services;
  • Ensuring internal quality control and safety;
  • Authenticating and verifying individual identities;
  • Carrying out audits;
  • Communicating with you about your account, activities on our Services and Privacy Notice changes;
  • Preventing and prosecuting potentially prohibited or illegal activities;
  • Enforcing our agreements; and
  • Complying with our legal obligations.

Marketing Our Products and Services. We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth below.

Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

Use of De-identified and Aggregated Information. We may use personal information and other data about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.

How We Use Automatic Collection Technologies. We, as well as third parties that provide content, advertising or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Services. Our uses of these Technologies fall into the following general categories:

  • Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
  • Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
  • Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
  • Advertising or Targeting Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third party sites.

Cross-Device Tracking. Your browsing activity may be tracked across different websites and different devices or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this our technology partners may share data, such as your browsing patterns, geo-location and device identifiers, and will match the information of the browser and devices that appear to be used by the same person.

INFORMATION WE OBTAIN FROM DATA PARTNERS

In order to provide our geospatial analytics Services, we obtain information from trusted third-party data partners about mobile devices that have visited an area of interest to us or our customers. This information may include:

  • Mobile advertising identifiers (e.g., Apple IDFA and Google Android IDs);
  • Precise geolocation and proximity of a device if location services are enabled (usually expressed in latitude/longitude coordinates along with a date and timestamp);
  • The horizontal accuracy of the latitude/longitude coordinates;
  • Dwell time near areas of interest;
  • Phone carrier and connection type (e.g., cellular, WiFi);
  • The direction in which the device is traveling as a degree coordinate and speed of the device;
  • Information about the device such as device type, model and OS type and version;
  • Device language;
  • IP address of the device;
  • Available or connected WiFi SSID and/or BSSID names;
  • Altitude and vertical accuracy;
  • Whether a device is charging;
  • Bluetooth connected/ available devices;
  • Bluetooth beacon proximity and any related metadata; and
  • Connected car details (including make, model, and year), location, and travel details (including route, distance traveled, direction, and speed)

Our third-party data partners receive this information through relationships they have with mobile applications. The mobile applications provide the information to our data partners via software development kits (“SDKs”) embedded directly into the mobile applications and through APIs which are interfaces through which these mobile applications can provide our data partners with information about their end users.

HOW WE USE INFORMATION WE OBTAIN FROM DATA PARTNERS

All Orbital Insight employees are required to maintain the privacy and security of personal information we obtain from data partners.

Research, Analytics, and Commercial Purposes. We use the information we obtain from our data partners for a variety of research, analytics, and commercial purposes, including traffic analysis (for instance, tracking what devices are within a certain area of interest at selected times and which parts of a city are most busy at selected times), analytics (for instance, footfall analysis based on device traffic), and market research (for instance, analyzing consumer shopping trends or business intelligence based on device traffic).

We typically carry out these activities to help our customers with a specific project or initiative. When we work with our customers, we present our analysis in an aggregate and/or de-identified manner and we do not share mobile advertising identifiers with our customers.

In some cases, we may also engage in these activities for our own purposes, including to develop and improve our Services.

OUR LAWFUL BASIS FOR PROCESSING

For purposes of the EU General Data Protection Regulation, our processing of the personal information we obtain from our data partners supported by the following lawful bases:

· Legitimate Interest: We process personal information to further our and our customers’ legitimate interests but only where such interests are not overridden by the interests or fundamental rights and freedoms of data subjects. Examples of these legitimate interests may include research, processing for historical and statistical purposes, and processing to carry out general business activities.

· Compliance with our Legal Obligations: We may process personal information to comply with our legal obligations.

HOW TO OPT OUT OF SHARING INFORMATION WITH DATA PARTNERS

You may be able to opt out of sharing your device’s mobile advertising identifiers (and geolocation data associated with it) with our data partners by adjusting the settings on your mobile device, including by following the instructions for Android and iOS. For devices that do not utilize Android or iOS, you may be able to use your device’s operating system controls in your settings to exercise choice. Please note that mobile operating systems may change these options in the future.

You can also use your device settings to disable the collection of geolocation data at the mobile application level. However, if you do so, certain services that rely on geolocation data to function may be affected.

Please note that adjusting your mobile device’s settings does not impact any device identifiers already in our possession. To exercise any of the rights you may have under applicable data protection laws in the information that we have obtained from our data partners, please see “YOUR PRIVACY RIGHTS” below.

DISCLOSING INFORMATION TO THIRD PARTIES

We may share information with the following categories of third parties:

Service Providers. We may share any information we collect with our third-party service providers. The categories of service providers to whom we entrust information include: vendors to support the provision of the Services; IT and related services; email services; and customer service providers.

Affiliates. We may share information with our affiliated entities.

Advertising Partners. When you visit our website, we may allow third party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering targeted advertisements to you when you visit third party services within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.” If you prefer not to share your personal information with third party advertising partners, you may follow the instructions below.

Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

INTERNATIONAL DATA TRANSFERS

All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

YOUR CHOICES – PERSONAL INFORMATION WE COLLECT FROM CUSTOMERS AND WEBSITE VISITORS

General. You may be able to opt out of certain uses of your personal information.

Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to this Privacy Notice).

“Do Not Track”. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these websites and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/.

Please note you must separately opt out in each browser and on each device.

YOUR PRIVACY RIGHTS

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your personal information or object to processing of your personal information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; (vi) withdraw your consent; (vii) object to our processing of your personal information; and (viii) request erasure of personal information held about you by us, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.

We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request. Please note that because we are unable to authenticate any individuals whose device information we obtain from our data partners, our ability to respond to and fulfill such requests will be limited and, in some cases, not possible.

DATA RETENTION

We store the information we receive as described in this Privacy Notice for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Orbital Insight has collected about them and whether Orbital Insight disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information below:

Category of Personal Information Collected by Orbital Insight

Categories of Third Parties Personal Information is Disclosed to for a Business Purpose

Identifiers

  • Service providers
  • Advertising partners

Personal information categories listed in Cal. Civ. Code § 1798.80(e)

  • Service providers

Commercial information

  • Service providers

Internet or other electronic network activity

  • Service providers
  • Advertising partners

Geolocation data

  • Service providers

Professional or employment-related information

  • Service providers

Inferences drawn from other personal information to create a profile about a consumer

  • Service providers
  • Advertising partners

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth above.

Additional Privacy Rights for California Residents

“Sales” of Personal Information under the CCPA. For purposes of the CCPA, Orbital Insight does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us as set forth below.

Verification. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include confirming the email address associated with any personal information we have about you.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth below. We will process such requests in accordance with applicable laws. Please note that because we are unable to authenticate any individuals whose device information we obtain from our data partners, our ability to respond to and fulfill such requests will be limited and, in some cases, not possible.

INFORMATION SECURITY

We take steps to ensure that the information we collect is treated securely and in accordance with this Privacy Notice. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information we collect. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

THIRD PARTY WEBSITES/APPLICATIONS

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

CHILDREN’S INFORMATION

The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected a child’s personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.

SUPERVISORY AUTHORITY

If you are located in the European Economic Area or the United Kingdom, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

CHANGES TO OUR PRIVACY NOTICE

We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you by posting an updated version of this Privacy Notice or as otherwise required by applicable law.

CONTACT US

If you have any questions about our privacy practices or this Privacy Notice, or if you wish to submit a request to exercise your rights as detailed in this Privacy Notice, please contact us at:

Orbital Insight, Inc.

3000 El Camino Real

Building 2, 4th Floor

Palo Alto, CA 94306

(650) 353-2060

support@orbitalinsight.com


Last revised: January 5, 2021