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.
PARTICIPATION IN INDUSTRY SELF-REGULATION
- We receive 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.
- In cases where Factual does not interact directly with consumers, we contractually obligate our partners 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 are required to provide notice and get consumers’ consent to share precise location data with us, and consent for Factual to share with third parties;
- Our partners are prohibited from sharing data with Factual where the user has not provided such consent;
- Our partners are required to respect platform signals that consumers can use to opt out of interest-based advertising; and
- Our partners are required to comply with the NAI Code of Conduct and the DAA Self-Regulatory Principles and applicable privacy laws.
- Other contractual protections:
- Our standard contracts prohibit partners from sending us any personally identifiable information (PII) or sensitive data, each as defined by the NAI.
- 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.
- 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.
- Factual continually reviews its products and services in order to implement appropriate privacy controls.
SERVICES IN THE EUROPEAN ECONOMIC AREA
- We design our services and contracts to comply with privacy regulations that apply in the European Economic Area, and we continue to review our practices as European requirements change.
- Factual is certified under the EU-U.S. Privacy Shield program, and we also comply with the Swiss-U.S. Privacy Shield framework; please see here for more information.
- Factual has elected to pause its Audience business in EU as of May 25, 2018, and continuing until further notice.