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

DATA PRACTICES

  • 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.

CONTRACT REQUIREMENTS

  • 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 display a conspicuous privacy policy that includes a description of the collection, use, processing, and sharing of personal information.
    • 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.

 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.
  • 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.

For more information about our data practices, please see our privacy policy or get in touch with us at privacy@factual.com.