FACTUAL’S PRIVACY PRACTICES

At Factual, we value consumer privacy and have designed our business accordingly. We offer a suite of location-based products to help companies enhance their services for consumers, based on the locations that consumers visit. Below is a summary of some of the steps that we take to protect consumers’ privacy in connection with our services. For more information about our data practices, please see our privacy policy or get in touch with us at privacy@factual.com.

PARTICIPATION IN INDUSTRY SELF-REGULATION

DATA PRACTICES

  • We do not use personal information to send direct marketing on behalf of our clients to consumers’ homes or email addresses.
  • We collect precise geolocation information and other relevant device data, typically through our partners.
  • We use this information to help our clients understand their customers, provide more relevant advertising and content, and enable location-based features in applications.
  • For more information, we invite you to read our privacy policy at https://www.factual.com/privacy.

CONTRACT REQUIREMENTS

  • In cases where Factual does not interact directly with consumers, consistent with industry standards, we obligate app publishers to obtain consent from their users to pass location data to us.
  • In our standard contracts, we require partners to take a variety of steps to give consumers notice and control related to data collection. For example:
    • Our partners must commit to provide notice and get consumers’ consent before they share precise location data with us;
    • Our partners must respect platform signals that consumers can use to opt out of interest-based advertising; and
    • Our partners must comply with the DAA Self-Regulatory Principles and applicable privacy laws.

PRIVACY PROTECTIONS

  • We do not offer services (or we limit our services) related to certain locations. Examples of these locations include pregnancy centers, women’s shelters and certain health and mental health treatment locations.
  • Consistent with the U.S. Children’s Online Privacy Protection Act, we prohibit our partners from providing us with personal information about children under 13 years old or from child-directed properties.
  • Our standard contracts restrict clients from categorizing users based on certain characteristics that could be considered sensitive.
  • Our standard contracts prohibit the use of Factual services for unlawful discrimination; or for adverse decisions related to employment, credit, health care treatment or insurance.

SERVICES IN THE EUROPEAN ECONOMIC AREA

  • We designed our services and contracts to comply with privacy regulations that apply in the European Economic Area, which differ in some respects from U.S. privacy law, and we continue to review our practices as European requirements change.
  • We were among the first group of companies to self-certify with the new EU-U.S. Privacy Shield program.