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GET IT® Privacy Policy

Effective Date: February 1, 2015

WE CARE ABOUT YOUR PRIVACY

We welcome your interest in GET IT, a service provided by GET IT Mobile, Inc.

GET IT allows content publishers to market their mobile apps and content throughout many venues, including websites, social networks, email or even offline media. Users simply enter their mobile phone number, email address, scan a QR code, text us a keyword or click on a get.it link and GET IT connects them with the advertised mobile app or content. GET IT also provides a mobile user acquisition service that allows content publishers to drive mobile app installs by leveraging our advertising service in a large variety of mobile apps and on mobile websites. This is the Privacy Policy for the GET IT service provided by GET IT Mobile, Inc

Table of Contents

1. Introduction

2. Personal Data that GET IT collects

3. Non-Personal Data that GET IT collects

4. How GET IT collects Data

5. What GET IT does with the Data and why we collect it

6. How we Share your Personal Data

7. How we Share your Non-Personal Data

8. How We Protect your Data

9. Children’s Privacy

10. Opt-Out

11. Data Removal

12. Your California Privacy Rights

13. Privacy Compliance and Contact Information

14. Enforcement and Dispute Resolution

15. Changes to this Privacy Policy

 

1. Introduction

GET IT is committed to protecting your privacy and to comply with applicable data protection and privacy laws. We hope that our Privacy Policy (“Policy”) helps you understand what kind of information we collect in connection with our GET IT service, how we process and manage such information and what steps we take to secure it. We only use your personal data with your consent and that is why we take the steps we do. We welcome questions or suggestions regarding the privacy of your information and always look for better ways to provide you with our products and services. Throughout this Policy, the term “personal data” means personally identifiable information relating to an individual (i.e. a natural person). “GET IT” refers to GET IT Mobile Incorporated, including all affiliates (also referred to as “we”, “us”, or “our”) and “GET IT service” or “Service” refers to our GET IT mobile app and content marketing and advertising service.

This Policy is part of our Terms of Service and applies to personal data and non-personal data (collectively “data”) that is collected in connection with our GET IT service.

This paragraph is only applicable to users who interact with our Service by entering their mobile phone number or email address on a website or Facebook, or users who scan a QR code or text us a keyword: By using the GET IT service, you are agreeing to the terms of this Policy and the terms and conditions of services in the Terms of Service, and you are agreeing to GET IT being able to collect, access, process, and/or retain the data that becomes available to GET IT when you access or use the GET IT service. Some of this information may be personal data in the USA, the EU or in other locations. GET IT collects, processes and retains such information in accordance with this Policy. If you do not agree with this Policy, please do not use our Service or provide GET IT with any such data. Our Service is often used as a feature of other companies’ websites, social network pages or otherwise. Our Service may also link to other companies’ websites and other third party services. All of these third party entities may have privacy policies of their own. We recommend that you read the privacy policies of such companies, as GET IT is not responsible for the privacy practices or contents of these third-party entities’ services.

This paragraph is only applicable to users who are redirected to our Service after clicking on a get.it link or on an advertisement in a mobile app or on a mobile website provided by a third party: Our Service regularly interacts with third party apps and websites. All of these third party entities may have privacy policies of their own. We recommend that you read the privacy policies of such companies, as GET IT is not responsible for the privacy practices or contents of these third-party entities’ services. If you have been redirected to our Service after clicking on a link or on an advertisement displayed by one of these third party entities, you acknowledge that you accept the practices and policies outlined in this Policy, and you are agreeing to GET IT being able to collect, access, process, and/or retain the data that becomes available to GET IT when you access the GET IT service. The data we collect from you when you interact with our links or advertisements is typically limited to your Internet Protocol (IP) address and information about your mobile device (e.g. device type and operating system). Some jurisdictions may consider IP addresses personally identifiable information. GET IT does not consider IP addresses personal data (see definition below). GET IT collects, processes and retains such information in accordance with this Policy.

GET IT Mobile Inc. has been awarded TRUSTe’s Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe’s program requirements including transparency, accountability and choice regarding the collection and use of your personal data. TRUSTe’s mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at privacy[at]getitmobile.com*. If you are not satisfied with our response you can contact TRUSTe here. The TRUSTe program covers only information that is collected through GET IT websites http://get.it and http://getitmobile.com,, and does not cover information that may be collected through software downloaded from the site and our mobile application.

GET IT Mobile Inc. complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. GET IT Mobile Inc. has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, please visit http://www.export.gov/safeharbor/.

2. Personal Data that GET IT collects

Personal data is considered information that either on its own or when combined with certain other information can identify an individual and could be used to contact you as an individual on-line or off-line. GET IT collects personal data when you use our Service (i.e. by submitting a mobile phone number, email address or text message to the Service) or otherwise interact with the Service or us. We collect personal data only with your knowledge or consent. Below are the types of personal data that we collect.

Personal data collected will vary depending upon the activity and it is usually limited to your mobile phone number or email address. Users who contact GET IT may be asked to provide their name, phone number, home address, birth date and mobile phone number. In that context, such users’ mobile numbers will only be used for text messaging in connection with the GET IT service. They will not be retained for any other purpose. GET IT may also collect Internet Protocol (IP) addresses or mobile device identifiers, which, in some jurisdictions, may be considered personally identifiable information. GET IT does not consider IP addresses or mobile device identifiers personal data.

3. Non-Personal Data that GET IT collects

We may share non-personal data and anonymous and/or aggregated data that does not personally identify you with our clients, business partners, the press and other third parties for any purpose. We share aggregated or anonymous data because we have removed personal identifying characteristics such that no individual can be associated with the information provided.

4. How GET IT collects Data

We collect data in the following ways:

Data You Submit. When you use the GET IT service, you may be asked to submit your mobile phone number or email address. In each such instance, you will know what personally identifiable data we collect, because you actively submit it. In addition, we will collect your mobile phone number when you connect to the Service by sending a text message to our short code. We collect this data to provision the Service and to identify returning users. We will use the personal data you voluntarily submit to us for the purposes we describe in this Policy, as well as any purposes that we describe to you when we collect such data.

Tracking Technologies. Technologies such as: cookies, beacons, tags and scripts are used by GET IT and our advertisers, service licensees, affiliates, or analytics or service providers. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

We use cookies to remember users’ settings (e.g. language preference), and for authentication. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.

Ad-Tracking. As is true of most web sites, we gather certain information automatically and store it in log files.  This information includes Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or site functionality. We also advertise mobile apps or websites of some of our clients on third-party advertising networks such as Google. When you click on one of our advertisements, certain non-personal data such as your IP address, device identifier, operating system information and other data may be collected by us. We do not use this data to identify individual users personally. In addition, the advertising network and the owner of the mobile app or website that features our advertisements may also collect the non-personal data outlined above as well as other data such as your device’s media access control (“MAC”) address, international mobile equipment identity (“IMEI”) address or your locale (location information based on IP address). These third party entities may have privacy policies of their own and data collected by these third party entities may be shared with us in accordance with their privacy policies. We recommend that you read the privacy policies of such third party entities, as this Policy does not apply to information received from third parties, and GET IT is not responsible for the privacy practices of such third parties.

Links to 3rd Party Apps and Websites. Our website and Service includes links to other mobile apps and websites whose privacy practices may differ from those of GET IT. If you submit personal information to any of those apps or websites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any mobile app you use and website you visit.

Social Media Widgets. Our website and certain Service elements include social media features, such as the Facebook Like button and it may include widgets, such as the Share This button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the company providing it.

5. What GET IT does with the Data and why we collect it

GET IT collects and processes data for two primary reasons: To make the Service more convenient for our users (i.e. by storing their mobile phone numbers for future use) and to provide our partners with non-personal data about the usage of the GET IT service. In addition, we may process your data for additional purposes, as described below. Please note that one or more purposes may apply simultaneously.

Provision of Service. We use your data to (i) fulfill your mobile app or content request, (ii) monitor your transactions to ensure the functionality and security of our Service, and (iii) identify you and to prevent and investigate fraud and other misuses. We may also use your data to personalize our Service to make it more relevant to you, for example, to display product availability, make recommendations and to display customized content and advertising.

Development of Products and Services. We may use your data to develop and enhance our products and/or services. However, for the most part, we only use aggregate and statistical information in the development of our products and services. We may combine personal data collected in connection with your use of our Service with other non-personal data we may hold about you, except where such personal data was collected for a different purpose.

Communicating with you and marketing. We may use your personal data to communicate with you, for example, to provide information relating to our Service and we may, in accordance with applicable law, contact you to inform you of new products, services or promotions we may offer. Our Service is primarily used to promote products of other companies. However, GET IT does not disclose your personal data to such companies or any other company for marketing purposes without your consent.

GET IT Analytics Tools and Technology. GET IT uses its own proprietary analytics tool and other analytics technologies to analyze the personal and non-personal data it collects when users visit and/or use our Service. We may anonymize personal data and provide statistical information based on your anonymized personal data and non-personal data to our clients for their business purposes. We also provide non-personal data about our users’ use of the GET IT service to our clients, the press and industry analysts. We do not provide any personal data to anyone without your consent.

Conversion Measurement. We may use certain elements of your non-personal data such as you mobile device’s IP address or identifier for advertising (IFA) and compare it with data received from third parties such as advertising networks (e.g. Google), mobile app install attribution analytics providers (e.g. Tune, Kochava) and our clients in order to verify if a particular action such as a mobile app install is attributable to our advertising.

6. How we Share your Personal Data

Our policy is that we do not sell, lease, rent or otherwise disclose your personal data to third parties unless for the reasons stated below.

Consent. We may share your personal data if we have your consent to do so (your “opt-in”).

GET IT clients and authorized third parties. We may share your personal data with authorized third parties who process personal data for GET IT for the purposes described in this Policy. Such parties are not permitted to use your personal data for any other purposes, and we require them to act consistently with this Policy and to use appropriate security measures to protect your personal data. We may also share your personal data with our clients who utilize our Service to provide you with mobile apps or content, but only to the extent (i) your personal data pertains to a product provided by such client (and not, for example, personal data pertaining to all transactions that you have conducted through our Service), and (ii) you have opted into receiving additional news or information from such client.

International transfers. The data we collect is stored and processed on servers in the United States and other locations around the world. By using our Service, you consent to the transfer of the data described in this Policy to locations that may be outside of the country in which you live, and to such places that may be in the United States, or to locations in other countries.

Mandatory disclosures. We may be obligated by mandatory law to disclose your personal data to certain authorities or other third parties, for example, to law enforcement agencies in the countries where we or third parties acting on our behalf operate. We may also disclose and otherwise process your personal data in accordance with applicable law to defend GET IT’s legitimate interests, for example, in civil or criminal legal proceedings. 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.

Mergers and Acquisitions. If we decide to sell, buy, merge or otherwise reorganize our businesses in certain countries, this may involve us disclosing personal data to prospective or actual purchasers and their advisers, or receiving personal data from sellers and their advisers. We will however take reasonable steps to assure that your personal data is used in a manner consistent with this Privacy Policy. You will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Messaging services. When you use our Service or otherwise interact with us over wireless telecommunications networks, certain personal data, such as your mobile phone number, will be transmitted to us as a standard part of that communication. This information may be recorded and collected by wireless service providers or wireless messaging service providers, and GET IT has no control over such collection of information.

7. How We Share your Non-Personal Data

We may share non-personal data and anonymous and/or aggregated data that does not personally identify you with our clients, business partners, the press and other third parties for any purpose. We share aggregated or anonymous data because we have removed personal identifying characteristics such that no individual can be associated with the information provided.

8. How We Protect Your Data

While there are always risks associated with providing personal data, whether in person, by phone, via the internet or otherwise, and no technology is completely safe or “tamper” or “hacker” proof, GET IT takes appropriate technical and organizational information security measures to prevent and minimize such risks. Such measures may include, where appropriate, the use of firewalls, secure server facilities, encryption, implementing proper access rights management systems and processes, careful selection of processors and other technically and commercially reasonable measures to provide appropriate protection for your personal data against unauthorized use or disclosure. All personal data that is entrusted to GET IT for transmission and processing will be used in a manner that is consistent with the purpose for which the information was intended. GET IT will not use or process this information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you. If you have any questions about security on our Web site, you cancontact us at privacy[at]getitmobile.com*.

9. Children’s Privacy.

Our Service is intended for people that are at least 13 years old. We do not intentionally or knowingly collect personal data from children under the age of 13, and individuals under the age of 13 are prohibited from using our Service, and are prohibited from submitting any personal data to our Service. If we inadvertently send an email or text message to a person that does not meet the age eligibility requirements of our Service (such as a child under the age of 13), the child’s parent or legal guardian always has the right and option to unsubscribe (opt-out) from receiving future emails or text messages via the unsubscribe mechanism described in the “Opt-Out” section below and we will delete that information immediately.

10. Opt-Out.

If you do not want us to collect, use and share the data we describe in this Policy please discontinue your use of the Service. You may also opt-out by asking us to remove your personal data from our servers. Use the Opt-Out form on www.getitmobile.com/account/ or send us a letter to the address in the “Contact Information” section below to make such request. For more information about removing your personal data, see the “Data Removal” section below. Please note that if you have granted us permission to provide your personal data to our client(s) or other third-party recipients, you would have to contact them separately with respect to opt-out requests as most of these entities have their own information privacy policies, which may differ from ours.

SMS App Link Delivery Opt-Out. If your are a user located in the United States and you have used our Service by submitting your mobile phone number to us, you may opt-out of receiving text messages sent by the Service at any time by sending an SMS message with the text “STOP,” to 42777 (or such other number as may be designated by GET IT). After you have opted out, you will no longer be able to use the Service until you re-start the Service by sending an SMS message with the text “START,” to 42777 (or such other number as may be designated by GET IT). If you would like to update your information, please contact us at the information listed below.

Resetting your Mobile Advertising Identifier.
We may access and use Apple’s and Google’s advertising ID’s, which are resettable identifiers that enable us to measure if a particular action (such as a mobile app install) is attributable to our advertising. Please note that if you are accessing our service with an iPhone, iPod, iPad or Android device, you can reset your advertising ID at any time.

Android: Apps making use of the Android advertising ID must check for and respect the user’s ad tracking preference. Also please note that any use of the advertising ID must abide by the terms of the Google Play Developer Content Policies. On your Android device, the advertising ID is made available to apps through APIs provided in Google Play services. You can reset your advertising ID at any time, right from the Ads section of the Google Settings app on your device. From the same app, you can also opt-out of targeted advertising based on the advertising ID by setting the appropriate ad tracking preference.

IPhone, IPod and iPad: You can opt out of targeted advertising by accessing the following link on your device: http://oo.apple.com. Alternatively, if you are using the iOS 6 or above operating system on your device, you may opt-out by electing Limit Ad Tracking (Learn More). If you opt out, you will continue to receive the same number of mobile ads, but they may be less relevant because they will not be based on your interests. You may still see ads related to the content on a web page or in an application or based on other non-personal information. Opting out through oo.apple.com applies only to Apple advertising services and does not affect interest-based advertising from other advertising networks.  However, if you select Limit Ad Tracking on your mobile device, third party apps are not permitted by contract to use the Apple Advertising Identifier, a non-personal device identifier to serve you targeted ads.

11. Data Removal.

If your personal data changes or if you no longer desire our service, you may correct, update, delete/remove by emailing our Customer Support at privacy[at]getitmobile.com or by contacting us by telephone or postal mail at the contact information listed below. After we receive your request to remove any personal data that we have about you, we will remove personal data about you from our Service within a reasonable time, but we may retain personal data about you in our non-public databases to support our operational requirements (for example only, back-up purposes). Notwithstanding the foregoing, we will retain your personal data as long as needed to provide you services. There may be circumstances where we are legally required to retain the data we collect about you (for example, in connection with court proceedings and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements) and despite your request for us to delete your personal data, we will retain what we are legally required to keep. Moreover, we reserve the right to anonymize the personal data so that it is no longer associated with you rather than deleting it. We also reserve the right to use previously obtained information to verify your identity or take other actions that we believe are appropriate.

12. Your California Privacy Rights

If you are a resident of the State of California, we provide you with information on how to exercise your disclosure choice options such as your right to opt-out (which we may sometimes refer to as “unsubscribe”) or opt-in for use of your personal data by third parties (such as our clients) for marketing purposes. Therefore, pursuant to the California Civil Code, we are not required to maintain or disclose a list of the third parties that received your personal data for marketing purposes during the preceding year. If you are a California resident and wish to request information about how to exercise your third party disclosure choices, please send a request by email to the Privacy Administrator at privacy[at]getitmobile.com* or by postal mail to GET IT Mobile, Inc.:

GET IT Mobile, Inc.

2880 Stevens Creek Blvd.

Suite 350

San Jose, CA 95128

Attn: Privacy Administrator

All requests must be labeled “Your California Privacy Rights” on the email subject line or envelope or post card. For all requests, please clearly state that the request is related to “Your California Privacy Rights”, include your name, street address, city, state, zip code and e-mail address (your street address is optional if you wish to receive a response to your request via email) and indicate your preference on how our response to your request should be sent (email or postal mail). We will not accept requests via the telephone or by facsimile. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

13. Privacy Compliance and Contact Information

GET IT Mobile Inc. 2880 Stevens Creek Blvd., Suite 350, San Jose, CA 95128, U.S.A. is the controller of your personal data. In matters pertaining to GET IT’s privacy practices you may also contact us at:

Privacy Compliance

c/o GET IT Mobile, Inc.

2880 Stevens Creek Blvd.

Suite 350

San Jose, CA 95128

U.S.A.

Email: Privacy Administrator to privacy[at]getitmobile.com*.

14. Enforcement and Dispute Resolution

GET IT Mobile Inc. ensures the availability of an affordable, independent recourse mechanism by which each individual’s complaints and disputes are investigated and resolved by reference to our privacy principles. For purpose of this Policy the independent resource mechanism for disputes between GET IT Mobile and complainants hat reside in the United States of America or Canada shall be TRUSTe. The independent resource mechanism for disputes between GET IT Mobile and complainants that reside outside of the United States of America or Canada shall be JAMS. GET IT also ensures adherence to these privacy principles by conducting in-house compliance assessments of our privacy practices. In the event these assessments discover non-compliant privacy practices, corrective action plans will be developed to resolve the identified gaps in compliance, as well as a preventative action plan to maintain that compliance. Any employees determined by GET IT to be in violation of our privacy principles will be subject to disciplinary action up to and including termination of employment. Any questions or concerns regarding the use or disclosure of personal data should be directed to the address provided in Section 13 above. GET IT will investigate and attempt to resolve complaints and disputes regarding the use and disclosure of personal data in accordance with this Privacy Policy. For complaints that cannot be resolved between GET IT Mobile Inc. and the complainant, GET IT Mobile Inc. uses TRUSTe (or JAMS for complainants that reside outside of the United States or Canada) as the independent recourse mechanism in dispute resolution pursuant to U.S. privacy regulation, the U.S. – EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework, as applicable.

15. Changes to this Privacy Policy

We may update this privacy statement 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 Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

This Privacy Policy was last modified on the date indicated above and is effective immediately.

Copyright © 2011-2014 GET IT Mobile Inc. – All Rights Reserved.

*Please replace the [at] placeholder with the actual @ symbol before using this email address to contact us.