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GET IT® Privacy Policy

Effective Date: July 16, 2014

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, and does not cover information that may be collected through software downloaded from the site.

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.

Cookies. From time to time when you visit a website or social network page that offers our Service, or when you click on a get.it link or mobile advertisement that connects to our Service, information may be placed on your personal computer and/or mobile device (collectively, on the “device”). This information is commonly stored in a “cookie”. Cookies are small text files stored in a web browser or cookie-enabled mobile app. Typically, cookies are used to recognize a device and they enable the collection of certain data about the device, including its internet protocol (IP) address, the device and browser type and the identifier of any referring apps or sites. In addition, GET IT cookies store a unique identification number that allows us to link your device to data that we may have already stored in our user database (such as your mobile phone number or email address in the event you have previously accessed the Service from a personal computer). GET IT cookies also store information about mobile apps that you have downloaded by means of our Service. Our use of cookies is intended to provide benefits to you, such as eliminating the need for you to re-enter information about your mobile device whenever you use our Service on the same device again, and to provide you with a “history” feature that offers easy access and sharing functions for mobile apps viewed or downloaded by means of the Service. We may also use our cookies for website traffic analytics, mobile app usage analysis and anonymous demographic profiling. If you do not wish to receive cookies, or want to be notified before they are placed, you may set your web browser to do so, if your browser so permits. In addition, all modern web browsers offer a function that allows for the deletion of cookies that are already stored (refer to the browser documentation for more details). Please understand that if cookies are turned off or deleted, you may not be able to use certain features of our Service that may enhance your experience. Some of our partners who use our Service may also utilize cookies on their websites or within their mobile apps. However, we have no control over these cookies once they are set.

Beacons and Pixels. GET IT may use so called web beacons (or “pixel tags”) in connection with some websites that offer our Service. However, we do not use them to identify individual users personally. Web beacons are typically graphic images that are placed on a website and they are used to count visitors to a website and/or to access certain cookies. This information is used to improve our Service. An example of GET IT’s beacon use is to find out how many visitors to a website actually access the GET IT service. Web beacons do not typically collect any other information than what your browser provides us with as a standard part of any internet communication. If you turn off cookies, the web beacon will no longer be able to track your specific activity. The web beacon may, however, continue to collect data of visits from your IP-address, but such information will no longer be unique. Some of our partners who use our Service on their websites may also use web beacons. However, we have no access to or control over these web beacons.

Ad-Tracking. We 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.

Blogs. Our website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at privacy[at]getitmobile.com*. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

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 Tracking. We may use certain elements of your non-personal data such as you mobile device’s IP address or advertising identifier and compare it with data received from third parties such as advertising networks (e.g. Google), mobile app install tracking providers (e.g. Has Offers) 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.

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.

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. If your are a user located in the United States and you have used our Service by submitting your mobile phone number, 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.

11. Data Removal.

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, 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 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.