Privacy Principles

Cinarra recognizes the importance of privacy protection for consumers. As a technology company utilizing location data, we adopt a privacy-by-design approach to ensure that our platform meets the highest privacy standards. These privacy principles define how we handle data to safeguard consumer privacy while complying with applicable regulations, including the California Consumer Privacy Act (CCPA). For more details, please refer to our Technology Privacy Policy. In case of any inconsistency between this document and the Technology Privacy Policy, the latter shall prevail.

Commitment to Transparency

Cinarra explicitly defines our privacy processes in our Privacy Policy. We require our network partners (mobile operators) and advertising partners (advertising networks and business partners) to provide appropriate disclosures to their respective subscribers and users regarding data collection and processing practices.

Consumer Rights under CCPA

We respect consumer choices regarding privacy and provide mechanisms to exercise their rights under the California Consumer Privacy Act (CCPA):

  • Right to Know: Consumers can request details on the categories and specific pieces of personal data collected.

  • Right to Delete: Consumers can request deletion of their personal data.

  • Right to Opt-Out of Sale: Consumers can opt out of the sale of their personal data.

  • Right to Non-Discrimination: Consumers will not be discriminated against for exercising their CCPA rights.

To exercise these rights, contact us at:

  • Email: privacy@cinarra.com

  • Mail:
    Cinarra Systems, Inc.
    25 Metro Drive Suite 230
    San Jose, CA 95110
    United States

Data Collection and Processing

Cinarra ensures a clear separation of roles and data flow between our network partners and advertising platform to enhance privacy protection:

  • Network Partner Data: All raw data, including device activity and precise location, remains within the network partner's secure environment and is processed in accordance with their privacy policies.

  • Cinarra’s Advertising Platform: Cinarra receives only anonymized and aggregated targeting criteria, ensuring that no personally identifiable information (PII) is processed within our advertising platform.

De-identification and Anonymization

To enhance consumer privacy, Cinarra employs de-identification technologies:

  • Hashed device IDs prevent direct user identification.

  • Aggregated data processing ensures that no individual user can be identified.

  • Precise location data is converted into broader geofencing segments before processing.

  • Cinarra does not track or log personally identifiable information or precise location data (e.g., latitude/longitude).

Security Measures

Cinarra implements strict security measures to protect data from unauthorized access, loss, or misuse, including:

  • Encryption of data during transmission and at rest.

  • Access control policies to ensure only authorized personnel can access data.

  • Regular security audits and assessments to identify vulnerabilities and ensure compliance.

Data Retention and Storage

  • Data collected through Cinarra’s platforms is retained for a maximum of 13 months before being anonymized.

  • All data is processed and stored in the United States, with no transfer of consumer data outside the country.

Consumer Choice and Opt-Out Mechanisms

Cinarra respects consumer choices and provides opt-out mechanisms to ensure transparency and control over personal data:

  • Consumers can opt out of targeted advertising through opt-out icons displayed on advertisements.

  • Users may also manage privacy preferences through mobile OS settings:

    • Apple: "Limit Ad Tracking"

    • Android: "Opt out of Ads Personalization"

  • Network partners may also implement additional opt-out mechanisms within their systems.

Commitment to Privacy

At Cinarra, consumer privacy is fundamental to our technology and business model. Our privacy principles ensure that we prioritize privacy in every aspect of our platform, services, and data partnerships.

Policy Updates

Cinarra reserves the right to update this Privacy Principles document at any time. If significant changes occur, we will notify users via email or an update on our website.