Technology Privacy Policy

Cinarra Systems ("Cinarra" or "we") is a mobile technology company. We provide software ("Analytics Software") to mobile carriers and wireless internet providers ("Network Partners") that process location data within their data centers while ensuring privacy protection. This setup prevents Cinarra from accessing detailed personal data or raw data.

Additionally, we offer a technology platform ("Advertising Platform") that processes information from Analytics Software to deliver relevant advertising messages to mobile devices and computers.

This Technology Privacy Policy explains how information is collected, used, and protected by our Analytics Software and Advertising Platform.

Legal Basis for Data Processing (CCPA Compliance)

Cinarra processes data in compliance with the California Consumer Privacy Act (CCPA).

Analytics Software and Data Processing

Cinarra’s Analytics Software is installed and operated within the data centers of Network Partners. This software processes the following types of data:

  • Hashed device identifiers (e.g., anonymized mobile device IDs, network identifiers)

  • General location data (e.g., city-level or regional geolocation data)

  • Advertising recommendation segments (aggregated, non-personally identifiable data)

Network Partners use this software under their own privacy policies and are responsible for obtaining appropriate consumer consent in compliance with CCPA. The Analytics Software does not process or store personally identifiable information (PII), such as email addresses or phone numbers.

The Analytics Software processes data in real-time and converts precise location data into broader geofencing-based segments. These segments are then anonymized and aggregated before being used for advertising purposes.

Advertising Platform and Data Processing

Cinarra’s Advertising Platform processes data to enable relevant ad targeting. The platform receives de-identified data from the Analytics Software and processes the following information:

  • Mobile OS advertising IDs (e.g., IDFA, Android Advertising ID)

  • IP addresses (used to determine approximate geographic location)

  • Device characteristics (e.g., model, manufacturer, OS version)

  • Ad delivery data (e.g., timestamp, app or website where the ad was displayed)

The Advertising Platform does not process any personally identifiable information (PII) and operates only with anonymized and aggregated data. This ensures that consumer identities remain protected throughout the data flow.

Consumer Rights (CCPA Compliance)

Under CCPA, California residents have the following rights regarding their personal data:

  • 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 privacy@cinarra.com.

Opt-Out Mechanism

Cinarra provides an opt-out mechanism through an opt-out icon displayed on advertisements. Clicking this icon directs users to our opt-out page:Users may also opt out via mobile OS settings:

  • Apple: "Limit Ad Tracking"

  • Android: "Opt out of Ads Personalization"

Data Transfers and Storage

  • All data processed by Cinarra’s Analytics Software and Advertising Platform is stored in secure environments within the United States.

  • We do not transfer consumer data outside the United States.

Security Measures

Cinarra implements industry-standard security measures, including:

  • Data encryption during transmission.

  • Access controls to prevent unauthorized access.

  • Regular security audits to ensure compliance and improve our security framework.

De-identification and Anonymization

Cinarra utilizes industry-standard techniques to ensure that consumer data is anonymized and cannot be linked to individuals. These measures include:

  • One-way hashing of device identifiers to prevent re-identification.

  • Aggregated data processing to prevent individual tracking.

  • Geofencing segmentation, which replaces precise location data with broader location categories.

Data Retention

  • Cinarra retains data collected through its Advertising Platform for up to 13 months.

  • After this period, data is anonymized and aggregated for statistical purposes.

Children’s Information

Cinarra’s services are intended for business use. We do not knowingly collect personal information from children under 13. If we discover such information has been collected, we will take steps to delete it.

Policy Updates

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