Privacy Policy

Last Modified: May 26, 2016

Sense360 Privacy Policy

This Privacy Policy (“Privacy Policy”) explains how Sense360 Inc. (“Sense360”) may collect, use and disseminate
information about you that it obtains. For purposes of this Privacy Policy, the terms “we,” “us” and “our” refer to Sense360.

  1. Sensor Data and Contextual Inferences

    Sense360 licenses sensor-intelligence technology (the “Sense360 Technology”) to mobile application developers. As a result, mobile applications that you obtain from others may include the Sense360 Technology (“Sense360 Enabled Apps”). When you install a Sense360 Enabled App on your mobile device, the Sense360 Technology enables that device, subject to your consent, to gather data from its GPS receivers, accelerometers, gyroscopes and other sensors, including, but not limited to, information about ambient light and about your device’s location, acceleration and orientation (the “Sensor Data”). Your device will transmit that Sensor Data to Sense360 or its vendors. Sense360 or its vendors will store your Sensor Data along with associated device identification.

    Using its proprietary algorithms, Sense360 may be able to draw inferences from your Sensor Data about your location or about activities in which you are then engaged (collectively, “Contextual Inferences”). If you use a Sense360 Enabled App, we may use the Sensor Data we collect to generate analytics or market research reports that we share with third parties. We may also share Contextual Inferences about you with the publisher of that application (the “App Publisher”). Our agreement with App Publishers requires them to notify their users of the collection of Sensor Data from users’ devices and of the use of that Sensor Data to draw Contextual Inferences. However, we do not control the use or disclosure of Contextual Inferences by App Publishers, so you should read your App Publisher’s privacy policy before downloading and using any Sense360 Enabled App.

  2. What Information Do We Collect?

    We collect Sensor Data. We endeavor to avoid collecting or storing any information that would allow us to associate any of the Sensor Data or any Contextual Inferences with you or your family specifically (“Personal Information”) unless you specifically consent (via an opt-in mechanism) to our collection of your Personal Information.

    However, we cannot guarantee that we will never receive or store any Personal Information without consent. Further, App Publishers with which we share Contextual Inferences about you will be able to associate those Contextual Inferences with you specifically whether or not you consent to our collection of your Personal Information.When you use a Sense360 Enabled App, we may also present you with surveys that ask questions related to Sensor Data we collected or ask market research questions. Your participation in these surveys is completely optional. If you do elect to participate, your responses may be used or shared for any of the purposes described in this privacy policy.

    If you are using an Android device, we may also collect your device’s advertising ID and use that ID to collect additional information about your device from third parties. You may opt out of this by simply enabling the “opt out of interest-based ads” option on your device. Please note that opting-out via this setting will not affect any information we have already collected. Click here for more information regarding the Android advertising ID and its options.

  3. Minors and Children

    The Sense360 Technology is not intended to be used by individuals under 18 years of age. As indicated above, Sense360 endeavors to avoid collecting any Personal Information without consent. However, no one under age 13 may provide any Personal Information to Sense360 under any circumstances. If we learn that we have collected Personal Information from a child under age 13, we will take steps to delete that information as soon as possible. If you believe that we might have any Personal Information from or about a child under 13, please send a detailed message to [email protected]

  4. Our Use of Information

    We may use your Sensor Data, Contextual Inferences about you and any other information we collect (including your Personal Information, your survey responses, and your Android advertising ID) (collectively, “Information About You”) to generate analytics or market research reports, to improve our proprietary algorithms and other technology, or for any other purpose. Further, we may use any Information About You to communicate with you, to prevent fraud and otherwise to protect our or third party rights or interests. Subject to applicable law, we do not make Information About You available to you.

  5. Sharing Information with Third Parties

    We will not disclose Information About You without your consent in a manner that would allow it to be associated with you specifically, except as follows:

    • We may share Contextual Inferences about you with the App Publishers of Sense360 Enabled Apps that you use. The App Publisher will be able to associate those Contextual Inferences with you personally. We do not restrict or control the use or disclosure that App Publishers may make of those Contextual Inferences, so you should review your App Publisher’s privacy policies before installing or using any Sense360 Enabled Apps.
    • We may share Information About You with our vendors or service providers for the purpose of enabling them to help us with services we provide to our licensees, subject to commitments by those vendors or service providers to use Personal Information that we disclose to them only for that purpose and to protect it from disclosure.
    • We may share Information About You in response to a law enforcement request or legal process, to protect our rights and property or those of third parties, or as otherwise permitted or required by law.
    • We may transfer Information About You if we sell our business or some or all of our assets in connection with a business merger or acquisition.
    • Additionally, in the following circumstances, we may disclose Information About You without your consent:
    • if we believe there is a serious and imminent threat to the life, health or safety of yourself or another person;
    • to investigate or report on activity which we believe on reasonable grounds to be unlawful;
    • if disclosure is required or authorized by law (for example, in response to a subpoena or where a regulatory authority has the power to request the provision of certain records or information);
    • if disclosure is reasonably necessary to enable an enforcement body to perform its functions, for example the prevention, detection, investigation, prosecution or punishment of criminal offences, or the preparation for, or conduct of, proceedings before any court or tribunal, or implementation of the orders of a court or tribunal; or
    • if we deem it necessary in our sole discretion to protect our legal and legitimate business interests.

    Nothing in this Privacy Policy restricts us from using or disclosing in any way any aggregate information (i.e., information that cannot reasonably be associated with any specific person or family), such as in aggregated analytics or market research reports.

  6. Protecting Your Information

    We take the security of your Personal Information seriously and have implemented policies and procedures, including technical measures, which are designed to help safeguard it. However, the Internet and computer technology is not 100% secure and we cannot absolutely ensure the security of any information. Sense360 does not accept liability for any unintentional disclosure of Information About You or a disclosure of Information About You that occurs due to a security breach of our systems or facilities.

  7. Changes to Privacy Policy

    This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. It may be necessary from time to time for us to modify this policy to reflect changes in the way we collect and use information or changes in privacy-related laws, regulations, and industry standards. Accordingly, we reserve the right to change this policy at any time by posting the revised policy on our website and updating the “last modified” date at the top of this page. We encourage you to refer to this policy on an ongoing basis so that you understand our current privacy policy, because we may have no other practical way to notify you of changes to this policy. If revisions to the Privacy Policy are unacceptable to you, you must cease using any Sense360 Enabled App.