PRIVACY STATEMENT- CALIFORNIA

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policies that apply to your use of the websites and applications made available by Mobile Posse, Inc. (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

This privacy statement only applies to our products and information practices. We are not responsible for the actions and privacy policies of third party websites, partners, or their services.

This Privacy Statement further provides you with instructions on how you can request to get your data under the CCPA, how you can instruct us to delete your data, and how to stop the “sale” of your information.

Here are instructions to obtain an accessible and printable version of this policy: Right click on this page and in the menu select “Print.”

Information We Collect

We offer two types of services: Content that we deliver through our software application loaded on your device (the “Applications”) and content we deliver through the web browsers on your device (“Web Services”)(we will refer to Applications and Web Services collectively as the “Services”).

Categories of Information Collected by Our Applications

We collect and use from the Applications the following categories of information. We also state whether this information is shared or “sold” to third parties.

1. Categories of Personal Information Collected or Used by the Applications: Identifying information about you.

Examples: Android Advertising ID and our own product ID, which we call the “MPID” (each, a “User ID”).

Primary Purpose of Collection:

Do we share or sell this data?: We store our data on third-party hosting services under agreement. We use third-party analytics services such as Google Analytics to analyze data on our behalf. This data cannot be reused by these services. We sell User ID to advertising networks to deliver advertising on our Applications.

2. Categories of Personal Information Collected or Used by the Applications: Internet or other electronic network activity information

Examples: We collect information on how a user interacts with our Applications, including IP address, user page views, device platform, the device language (e.g., English or Spanish), device model, views of first screen deliveries, date and time when a user interacts with our Applications, operating system of the user’s device, Application version, the type of browser, the type of content delivered to the user (e.g., entertainment news), and the number of clicks per session.

Primary Purpose of Collection:This information helps us assess what features and content are of interest to its users and to measure the Services’ efficiency in delivering its services.

Do we share or sell this data?: We store our data on third-party hosting services under agreement. We use third-party analytics services such as Google Analytics to analyze data on our behalf. This data cannot be reused by these services. We do not sell this data or share it for marketing purposes.

3. Categories of Personal Information Collected or Used by the Applications: Geolocation

Examples: The Services collect your location from your device when you access the Services. This data is not shared with third parties.

Primary Purpose of Collection:Location information helps us provide you with content relevant to your region, such as local weather forecast and regional news.

Do we share or sell this data?: We store our data on third-party hosting services under agreement. We use third-party analytics services such as Google Analytics to analyze data on our behalf. This data cannot be reused by these services. We sell geolocation to advertising networks to deliver localized advertising on our Applications.

Categories of Information Collected by our Web Services.

The information we collect from you related to the use of the Web Services may include the following:

1. Categories of Personal Information Collected or Used by the Web Servides: Identifying information about you.

Examples: Our own Application ID (we call it the “MPID”).

We also collect the make and model of your devices (but not its specific device ID) and information about your version of the Application.

Primary Purpose of Collection:

Do We Share or Sell this Data?: We store our data on third-party cloud services and use third-party analytics services (e.g., Google Analytics) solely to analyze data on our behalf. We do not sell the MPID from Web Services.

2. Categories of Personal Information Collected or Used by the Web Services: Internet or other electronic network activity information

Examples: We collect information on how a user interacts with our Web Services, including IP address, user page views, device platform, the device language (e.g., English or Spanish), device model, views of first screen deliveries, date and time when a user interacts with our Applications, operating system of the user’s device, the type of browser, the type of content delivered to the user (e.g., entertainment news), and the number of clicks per session.

Primary Purpose of Collection:This information helps us assess what features and content are of interest to its users and to measure the Services’ efficiency in delivering its services./p>

Do We Share or Sell this Data?: We store our data on third-party cloud services and use third-party analytics services (e.g., Google Analytics) solely to analyze data on our behalf. We do not sell this data from our Web Services.

3. Categories of Personal Information Collected or Used by the Web Services: Geolocation

Example: We collect latitude and longitude information from your device when you are using the Web Services.

Primary Purpose: Location information helps us provide you with content relevant to your region, such as local weather forecast and regional news.

Do We Share or Sell this Data?: This information is stored on third-party services on our behalf and shared with analytics services such as Google Analytics for our internal business purposes. This information is not sold.

Categories of Information that We Do Not Collect

We do not collect or share the following categories of personal information:

We will retain as permitted under the CCPA certain data analyzed and processed by us, such as when a user has accepted our terms for the Application and such other data reasonably anticipated within the context of our relationship with you or solely for internal business purposes.

How we Use Your Information

In addition to the primary purposes of collection noted above, we may generally use the categories of information noted above as follows:

Sharing Personal Information

We may share your Information from our Services with data hosting services and analytical services to provide us with business, professional or technical support. Subject to your right to opt-out, we also share User IDs (but not location or activity information) from our Applications with advertising networks to provide you with offers that may be of more interest to you. Please note: We do not share User IDs, location or activity information with Advertisers from our Web Services. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties: Service Providers, which include data hosting services and analytics services that process information on our behalf under a written contract and Advertising Networks.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Under the CCPA, we have a right to verify your request. Important: Since we do not collect email addresses, numbers or names, the only way we can verify your request is if you provide us with us with your User IDs (Android Ad ID and MPID). The easiest way for us to verify your request is (a) if you click the “Do Not Sell My Information” on the Application on your device, or (b) for other requests, click on the “Give Me My Data” or “Delete My Data” links below. These links automate the process. We also provide instructions below if you desire to submit your requests via toll free number or through an authorized agent.

Right to Know: Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Please note we delete user data that is older than 3 months.

Once we receive and confirm your verifiable consumer request, we will disclose to you:

You can submit your request by:

Clicking on the “Give Me My Data” link at the bottom of this page.

Call 1-866-304-3097.

Right To Delete Data

You have the right to request that we delete any of your Information collected and retained by us subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

Exercising Deletion Rights

You have a right to ask us to delete your data. You can submit your request by:

Clicking on the “Delete My Data” link below.

Calling us at 1-866-304-3097

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may stop all information collection by uninstalling the Application. You may use the standard uninstall processes available as part of your mobile device or uninstall the App through your device’s Google Play store.

There are some instances in which you may not be able to uninstall some older versions of the Applications preloaded on your device. In that case, the Application can be force stopped by clicking on the “Settings” icon, then click on Apps & Notifications, then “See All apps”, and then click on the Application link. You will then have the option to “Force stop” the application, and clear information stored in memory by clicking on “Storage & Cache” then “Clear Storage” and “Clear Cache”.

Right to Opt-Out of the Sale of Personal Information

Users of Applications have the right to opt-out of the sale of Personal Information collected as part of the Applications. Users can submit their requests by:

Launch your version of the Application on your device, Click on the “Settings” icon, and then click “Do Not Sell My Info.”

Calling us at 1-866-304-3097

Right to Designate an Authorized Agent

Users of the Services can designate an authorized agent to make a request under the CCPA if they provide that agent with their User ID information. Please note that this action would allow such agent access to all information contained in the Application. If a user chooses to take this action, they do so entirely at their own risk and we disclaim all responsibility and liability for how such agent may access, use or disclose the information they obtain.

The agent will need to have your User ID to make a request. We are not able to identify a user based on name or email address since we do not collect this information. Agents must submit requests to privacyact.fotoscapes@mobileposse.com. Users can provide their User ID information using the process described below.

Finding the Android Advertising ID and Mobile Posse ID.

In order to verify your request under the CCPA, we will need your User ID (again, that is the Android Advertising ID and the MPID). The easiest way to verify your request is by (a) using the “Do Not Sell My Information” in the Application’s Settings area on your device, or (b) for other requests, go to the “Get My Data,” or “Delete My Data” links below. These links automate the process. If you contact us toll free number or an agent, our representative may ask you or your agent to locate your User IDs. You can find the Google Android Advertising ID by clicking on the “Settings” icon on your device, click on “Google” and then click on “Ads.” There you will see a string of letters and numbers that make up your Google Android Advertising ID. In the event you are asked to provide an MPID, please follow this process: To find the MPID, launch the Application on your device. Click on the “Settings” icon (the gear icon). Click on “Send Feedback.” When you click on Feedback, you will see a pre-populated email page. You will see on this email page a string of numbers and characters that make up your MPID. Copy that ID and to share with us so that we can act on your request.

Limitations on the Number of Requests

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. If we are unable to link your request with your User ID, we will provide you instructions on how you can locate your User ID on your device. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. We will retain this information in accordance with the CCPA.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Children Under the Age of 16

Our Services are not intended for children under 16 years of age. No one under age 16 may provide any personal information on our Services. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on our Services. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at the email address below.

Non-Discrimination

We provide our services at no cost to you. Unless permitted by the CCPA, we will not discriminate against you for exercising any of your CCPA rights.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 1-866-304-3097
Website: www.mobileposse.com
Email: privacyact.fotoscapes@mobileposse.com
Postal Address: Mobile Posse, Inc.
Attn: CCPA
1010 N. Glebe Road, Suite 800
Arlington, VA 22201

Updated: 31 December 2019

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