Cinarra's Technology Privacy Policy

Cinarra Systems (“Cinarra”, “we” or “us”) is a mobile technology company. We offer software (our “Analytics Software”) that enables mobile operators (our “Network Partners”) to process location information in their data centers. We also offer a technology platform (our “Advertising Platform”) that processes information from the Analytics Software, enabling the Advertising Platform to deliver relevant advertising messages on mobile devices. This privacy policy (“Policy”) explains how information is collected and used via the Analytics Software and the Advertising Platform. If you want more information about our privacy practices with respect to our website, please click here.

Cinarra’s Analytics Software

Data Collection and Use by our Network Partners

Cinarra’s Analytics Software is installed in Network Partners’ data centers. Network Partners process data via Cinarra’s Analytics Software in accordance with their data security and privacy policies and all Cinarra Analytics Software data is owned by Cinarra’s Network Partners.

Cinarra’s Analytics Software does not process personally identifiable information (“PII”) such as email or telephone numbers. Our Network Partners use the Analytics Software to process certain information to send ad recommendations via the Advertising Platform. The information that the Cinarra Analytics Software processes within the confines of a Network Partners’ data center includes: a hashed device ID (using a one way hash that makes recovery of the actual device ID impossible), precise location (e.g., lat/long), and general location (e.g., city) information from mobile devices. Cinarra relies on Network Partners to obtain any necessary permissions from their subscribers where required. The Analytics Software processes this information in near real time and renders any precise location information into non-precise GEO fence segments. The non-precise GEO fence segments are then further processed into ad recommendation segments that are not personally identifiable.

Cinarra’s Advertising Platform

Cinarra’s Advertising Platform does not process personally identifiable information (“PII”) such as email or telephone numbers. We process non-personally identifiable information via the Advertising Platform.

Data Obtained from the Analytics Software

Once processed into non-personally identifiable ad recommendations via the Analytics Software as described above, this information is associated with a hashed pseudonymous identifier (the “Statistical Index”) provided by the Network Partner. The Statistical Index and the ad recommendations are then transferred into the Advertising Platform. No location information, personally identifiable information or sensitive information is transferred into the Advertising Platform.

Data Collected Pursuant to Delivering Ads

The ad recommendations are then used pursuant to purchasing ads on advertising networks and exchanges (via our “Advertising Partners”) in order to serve tailored advertising messages on mobile devices. In doing so, Cinarra obtains certain publically available information about mobile devices from our Advertising Partners. This information includes, but is not limited to: the advertising identifier received from the mobile operating system (e.g., IDFA or Android Advertising ID), the IP address and the device model, manufacturer and device O/S version. We also receive information about the ads served, such as the date/time when the ad is served and the mobile application or website on which the ad is served. We use all this information to better target ad messages and for ad delivery and reporting purposes. Our Advertising Platform does not directly place cookies at this time, however our Advertising Partners may place cookies for ad serving and ad targeting purposes and their practices are not governed by this privacy policy. If at any point in the future Cinarra does place cookies, we will update the tech privacy policy.

Opting Out (our Choice Mechanisms)

Where required, we place an icon on ads delivered via our Advertising Partners. Clicking on the opt-out icon brings users to our informational page at https://www.cinarra.com/optout.html where end users can exercise their opt-out choices.

In addition to the opt out mechanism enabled by an opt out icon, when we receive other opt out preferences from our Advertising Partners via the ad preferences set from a mobile device, we do not serve targeted ads to those devices. The Android Advertising ID and Apple iOS’ IDFA are examples of advertising identifiers. Cinarra does not take action in response to Do Not Track signals coming from Internet browsers.

Information Security

The security of your information is important to us. Cinarra has implemented reasonable security measures to protect the information in our systems, both during transmission and once it is received. This includes, but is not limited to, the use of firewalls and encryption. No method of transmission over the Internet or method of electronic storage is 100% secure; therefore, while the company strives to use commercially acceptable means to protect your information, it cannot guarantee absolute security.

Data Retention

We store information collected via our Advertising Platform for up to 13 months. After 13 months, we may aggregate the information and store it without restriction.

Data Sharing, Onward Transfer

We may share non-personally identifiable information under the following circumstances:

  • With third party vendors and other service providers who work for us and need access to your information to do that work. These third parties are prohibited from using the information for purposes other than performing services for us;
  • To comply with laws or to respond to lawful requests and legal process and in order to investigate, prevent, or take action regarding suspected, or actual prohibited activities, including but not limited to fraud and situations involving potential threats to the physical safety of any person;
  • To protect the rights and property of Cinarra, our agents, customers, users, and others including to enforce our agreements, policies and terms of use;
  • In connection with or during negotiation of any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company.
  • We may also share aggregated or anonymized information without restriction.

Information Relating to Children

Cinarra’s Advertising Software and Analytics Platform are not designed to serve advertisements to those under 13 years of age. We do not knowingly collect PII from anyone under the age of 13. If the company is made aware that it has received PII from someone under 13, it will use reasonable efforts to remove that information from its records.

Third Party Websites

Cinarra serves ads that may link to third party websites. Such websites may use cookies and/or other data collection tools. Cinarra is not responsible for the privacy practices, policies or the content of such websites. This Privacy Policy does not cover the use of cookies and/or other data collection tools by any third party.

Changes to Privacy Policy

Cinarra may from time to time change its Privacy Policy. In the event that changes are made that we believe are material, we will update our Privacy Policy on this page of our website.

Questions and Concerns

If you have questions about Cinarra’s privacy practices, you may contact us at:

Cinarra Systems
2350 Mission College Blvd, Ste 470
Santa Clara, CA 95054
USA
email: privacy@cinarra.com

Last updated: November 19, 2015

 

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