Effective Date: October 11, 2021
Accordingly, this Policy explains how POLTE will collect and use information that we collect or otherwise obtain in connection with our cloud location over cellular services platform and related and related services and websites (such as https://www.polte.io) that link to this Policy (collectively, our “Services”). By using our Services, you agree to the collection, use, and disclosure of your information as described in this Policy. Beyond this Policy, your use of our Services is also subject to our Terms of Service.
Acceptance of the POLTE Terms of Service is also an acceptance of this Policy.
1. Scope and Applicability of this Policy
Your use of our Services may be governed by the privacy and use policies of third parties, for example a wireless carrier. Your POLTE enabled device sends non-personally identifiable information to our Services, and from which the location of the POLTE enabled device is determined. That transmission may be governed by the privacy and use policies of a wireless or other carrier. This Policy does not amend or abridge such third-party privacy or use policies.
2. Overview of our Services
The POLTE SaaS is intended to track and locate things through the use of connected devices, also known as the Internet of Things (IoT). You acknowledge and agree that: (i) you will not use our Services to track individuals without their express prior written consent and (ii) POLTE may terminate your use of the SaaS if we believe that you are using our Services to track individuals without their express prior written consent .
Location Determination, Location-Based and IoT Services. POLTE provides APIs designed to access and use our Services that may be used to calculate the approximate geographic location of a POLTE enabled IoT device. Those APIs allow a user of our Services to view and display geographic locations of the enabled device over time, when used in conjunction with a mapping program. In some instances, POLTE may also provide a mobile application for viewing location of an enabled device. Our Services include geolocation technology that determines the location of an enabled device by utilizing certain cell tower information sent from the device to our Services.
This information is then processed on POLTE’s servers to calculate and return the approximate geolocation (i.e., latitude/longitude) of the enabled device. We may also assign a unique hashed device identifier to location requests. The information sent from the enabled device to our Services does not contain personally identifiable information of a device user, but it may contain a unique identifier of an enabled device. POLTE may also provide location-based services and IoT services that utilize the location determination information. Such services may include mapping of assets on a visual display, configuration updates for IoT devices, and other insights that are derived from the location information and other data provided to POLTE by user devices.
3. Information Obtained via our Services
POLTE may collect the following types of information in connection with the use of our Services:
- Precise geolocation information (latitude/longitude);
- The IMEI of your enabled device;
- Information regarding the identity (e.g., Cell ID) of cell towers in proximity to an enabled device, along with certain wireless signal measurements;
- IP Address of a requesting device;
- A unique hashed device identifier (but not an IMEI or MAC Address) assigned to location requests;
- Time that a device is detected at a given location;
- Sensor information such as barometric pressure, accelerometer measurements, gyroscope measurements, device orientation, magnetic field measurements, direction of travel, motion activity (e.g., walking), or other similar sensor measurements;
- General information about the enabled device, including the device manufacturer, model, platform or operating system, time zone, network status (connected to wireless network, etc.), timestamp and other similar information; and
- Your account information, which may include personal information such as your name, at least one enabled device identifier (an IMEI) and at least one means of contacting you to provide customer support and for notices (address, phone number, or both).
4. Information Obtained from Partners and Collected by Partners
Our third-party partners (“Partners”) may be responsible for charging you for use of our Services. Data or information provided to a Partner for billing purposes is not collected or stored by POLTE. POLTE will, however, store account information and may receive current status regarding that account from our Partners (e.g., paid, suspended, etc.). In those limited circumstances, POLTE will bill according to actual use of our Services.
5. How We May Use Information
POLTE may use the information it collects or otherwise obtains in connection with its Services:
- To provide, maintain, debug, improve, and enhance our Services;
- To understand and analyze how you use our Services, and develop new products, services, features, and functionalities;
- To understand and analyze usage patterns;
- To improve the quality, accuracy and precision of POLTE’s SaaS location database by adding or refining the location of cell towers from which POLTE determines a device location;
- To assist in the display of the location of enabled to devices to you, on either a real time basis or over a period of time by providing a latitude, longitude and confidence ring of location for an enabled device;
- To infer relationships and linkages between enabled devices and location, such as a relationship between or an IMEI to a particular building, address or location;
- To generate de-identified and aggregated data to be used or shared for any lawful purpose.
- To find and prevent fraud, and respond to trust and safety issues that may arise;
- For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
- For other purposes for which we provide specific notice at the time the information is collected.
6. Data Retention and Data Security
Data Retention. POLTE takes measures to delete your information or keep it in a form that does not permit identifying you when your information is no longer necessary for the purposes for which we process it unless we are required by law to keep your information for a longer period When determining the specific retention period, POLTE considers various factors, such as the type of service provided to you, the nature and length of POLTE’s relationship with you, and mandatory retention periods provided by law, and the statute of limitations.
POLTE will retain six months of time series location and sensor data online, made available through APIs and reports. POLTE will retain an additional six months of time series location and sensor data in archival form, which you may be request be provided to you at any time by submitting a customer support request to email@example.com. You may purchase data storage beyond the retention periods described in this section in accordance with our Terms of Service.
Data Security. We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, as no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.
7. How We May Share Information
Except as described in this Policy, POLTE will not share any information that is collected by our Services with third parties. POLTE may share information that we collect from our Location Services or obtain via partners as follows:
- With our customers in connection with the provision of our Services;
- With other companies to provide data analysis, location-based action and insights;
- With third-party market research and information companies to create anonymous data, market research, business intelligence, or information products that analyze and monitor location behavior;
- With agents, vendors, or service providers ;
- To comply with legal requirements or to respond to a subpoena, search warrant or other legal process or government request received by POLTE, whether a response is required by applicable law;
- When POLTE believes that disclosure is necessary, in our sole discretion, to protect our legal and contractual rights or the safety of others or to investigate fraud;
- POLTE may disclose and transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our business or assets; or
- Where you have granted us permission.
8. Children’s Privacy
9. Cross-Border Transfers
Our Services are hosted in the United States (“U.S.”) and intended for visitors located within the U.S. If you choose to use our Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your information outside of those regions to the U.S. for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By providing any information, including information, on or to our Services, you consent to such transfer, storage, and processing.
10. Marketing Communications
We do not rent, sell, or share information about you with nonaffiliated companies for their direct marketing purposes unless we have your permission.
With respect to individuals in the European Economic Area, the United Kingdom, and Switzerland who use our Services, the following policies, clarifications, and rules also apply.
A. Key Terms
As used in this Section 11:
- “Personal Data” means any information relating to an identified or identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of such natural person.
- “Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
B. Purposes and Legal Bases for Processing Personal Data
POLTE processes data for the purposes as set forth in this Policy, including to make our Services available for use by our customers. To fulfill these purposes, POLTE may access information, which may include Personal Data, to provide our Services, to improve our Services, to develop additional products or features, or in response to contractual requirements. Please see the sections above for additional details on how we collect, use, disclose and share data, make automated decisions and retain data, including Personal Data.
In general, the lawful bases for POLTE’s Processing of Personal Data are: (i) informed consent, including as obtained via partners through contractual requirements and/or established consent frameworks or (ii) any other applicable legal bases, such as our legitimate interest in and compliance with industry practices.
In particular, with respect to processing, retention and use of any device-identified location data which may constitute Personal Data (i.e., location history that is associated with an IMEI or another persistent Device ID, hashed or otherwise – as opposed to data which is aggregated and not able to associated with any particular device), POLTE relies upon the informed consent of the end user, as received through our customers and partners.
With respect to the collection of the approximate location of wireless cell site information (cell site identifier, cell site specific information, and location-related information), if any, POLTE relies upon legitimate interest as a basis for collection and processing.
The foregoing statements of legal bases for processing are intended to be non-exhaustive, and do not preclude POLTE’s reliance on additional legal bases either now or in the future.
C. Additional Rights for Individuals in Europe
You may have one or more of the following additional rights available to you:
Access. Except for customer account information (voluntarily provided by you to use our Services), which you acknowledge and agree is true and correct, POLTE does not maintain any information regarding names, e-mail addresses, home addresses, or payment information, nor do we attempt to link any location data to such fields. Accordingly, while you may request a copy of the Personal Data we have collected from you by contacting us at firstname.lastname@example.org, you must provide your account number and name in order for POLTE to locate any information that might constitute Personal Data.
Objection/Opt-Out/Erasure. To object to or correct Personal Data about you (e.g., online identifiers such as an Advertising ID or IP Address) being Processed for direct marketing purposes, if any, you may contact us at email@example.com. In addition, as described above, you may request to opt-out from POLTE’s use of certain online device identifiers (including MAC Address, or IP Address), by submitting a Support ticket here. If you object to POLTE’s use of the IMEI, you must cease using our Services. In general, upon receipt of an opt-out request, within a reasonable time, POLTE will delete any collected data about any objected-to online identifier from POLTE’s database and quarantine the identifier so that POLTE does not collect any future data or share any information about the online identifier.
Right to Lodge a Complaint with a DPA. If you believe our Processing of Personal Data about you is inconsistent with the applicable data protection laws, to lodge a complaint with your local supervisory data protection authority (“DPA”).
To exercise any of the above-listed rights (with the exception of the right to lodge a complaint with a DPA, which you may do directly to a DPA), please contact us at firstname.lastname@example.org. We will process any requests in accordance with applicable law and within a reasonable period. We may need to verify your identity before processing your request.
12. Compelled Disclosures
We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (i) comply with law enforcement requests and legal process, such as a court order or subpoena; (ii) respond to your requests; or (iii) protect your, our, or others’ rights, property, or safety.
13. Updates to this Policy
We will post any adjustments to the Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share information previously collected from you through our Services, we will attempt to notify you through our Services, by email, or by other means.
14. Contact Information
If you have any questions, concerns or a complaint regarding our privacy practices, or if you would like to exercise your privacy choices or rights described in this Policy, please email us at email@example.com or write to us at:
15301 Dallas Parkway
Addison, Texas 75001