Privacy Policy for End Users

Verve Wireless, Inc. (“Verve”) is committed to protecting consumer privacy and to clearly informing users about the collection and use of information.

This policy covers information that is collected and used by Verve’s advertising and data services (“Services”). For information collected at the Verve corporate web site, please refer to the “Information collected at the Verve Corporate Web Site” section below. For the privacy practices for companies using Verve’s technology to provide mobile apps or web sites or for text messaging (“Publishers”), please see the applicable policies available from that company’s web sites or apps. If an app or web site you visit provides only a link to the Verve privacy policy and Verve is the publisher of that site or app, the Verve privacy policy (“Privacy Policy”) will be applicable.

When we use the phrase “Personal Information” in this Privacy Policy, we mean contact information (e.g., name, address, email address, or telephone number) and any other information that is used to personally identify an individual. When we use the phrase “Non-Personal Information” in this Privacy Policy, we mean information that is not be used to personally identify an individual or data that can be linked to an individual device but where technical, contractual and legal measures are in place to prevent the identification of an individual.

By visiting or using Services, you are accepting the policies and practices described in this Privacy Policy. We do not knowingly collect Personal Information from any child under 13 years of age. If we are informed or become aware that our Services are being used on a site or app directed at children, we will restrict the use of ad serving information to uses permitted under the Children’s Online Privacy Protection Act.

This Privacy Policy describes our practices with respect to Personal Information and Non-Personal Information.

Personal Information

We only collect Personal Information when you knowingly and voluntarily provide it to us, such as when you provide us feedback or request information from us. You do not have to provide Personal Information to use our Services and we do not collect Personal Information through our Services except as described in this Privacy Policy. Verve does not collect the phone numbers or the unique hardware device IDs of mobile devices.

Verve may identify your device using an anonymized (cryptographically hashed) hardware device ID, device manufacturer- or operating system-supplied ID meant for advertising use (e.g., Apple’s Advertising Identifier), or a randomly assigned unique identifier. The advertisements delivered by Verve may include forms or other prompts that allow users to opt-in to share data. However, it is your choice whether or not to provide that data.

If you use a particular Publisher’s mobile app or web site, that application or mobile website may independently collect information from you. For example, a Publisher’s use of Services may include text messages, in which case the Publisher will provide Verve with the applicable phone numbers.

When using a particular application or mobile website, you should familiarize yourself with the given Publisher’s terms and conditions and privacy practices. Verve is not responsible for, and cannot control, a given Publisher’s privacy practices. In the event Verve is the publisher of a particular app or web site, Verve’s policy will apply.

Location Data

In order to make advertising messages as relevant as possible to users, precise location data may be used for targeting ads and as input into location targeting segments based on high-level characteristics of locations. Location data is also used to aggregate impressions, clicks, and other interaction metrics to modeled household locations for the purposes of demonstrating marketing impact of advertiser campaigns. Location data that you provide to an app or web site may be provided to Verve to be used at that app or site or for ad serving or reporting when you use other apps or sites using our services.

You can opt-out of the use of precise data for location-based tracking by using the settings available on your mobile device. Ads will continue to be selected for you based on more general information, such as location that can be inferred from Internet Protocol (IP) addresses or other data.

Non-Personal Information

From Services that utilize mobile websites or HTML: we collect information automatically when you use our Services both through the use of log files and alpha-numeric identifiers known as “cookies” that are usually stored with the device’s web browser. This Non-Personal Information we collect via Services includes your IP address, browser type, browser language, device type and version, the date and time of your request, amount of data transferred, the source of your request (page referrer), and the nature of the content delivered to you. We generally use cookies to help with customer tracking and to reduce the time it takes for pages to load into your browser.

Our cookies do not contain Personal Information. We may use both session cookies (which expire once you close your web browser) and/or persistent cookies (which stay on your device until you delete them) to provide you with a more personal and interactive experience. Persistent cookies can be removed or blocked by following the directions in your Internet browser. We also use log files and cookies to improve the quality of Services and pages you have visited on the Services. Third parties, such as analytics vendors, may provide services to us or to Publishers and advertisers and they will also collect Non-Personal Information from you.

From Services that utilize mobile applications: In addition to the advertising identifiers described above, Verve will collect information about the type of app you are using and details such as IP address, device type, carrier, and operating system. Verve utilizes this information to uniquely identify mobile devices to deliver targeted marketing messages to consumers. We believe that the presentation of relevant marketing messages assists in providing a more meaningful mobile web experience. For example, this technology enables Verve to limit the number of times a specific message is presented to a consumer (frequency capping), to support product category preferential marketing, and to deliver advertising based on your location.

Web Beacons

We may permit Publishers and advertisers to use a software technology called pixels (a.k.a., web beacons), which are tiny graphics with a unique identifier, similar in function to cookies, used to report non-personal individual or aggregate information and help us better manage content on our Services. In addition, we may use pixels in our advertisements to let us know which ads have been viewed or to help tailor advertising.

Information from Third Parties

We may also get information about you from other sources. We may add this to information we obtain from your use of Services.

Advertising and Data Services and Your Choices

Verve uses Non-Personal Information as described above to help tailor which ads are displayed to you as you visit web sites or apps using our Services. Information that Verve collects as you visit a web site or app will be used to create an ad serving profile used to determine the ads displayed and to report about the effectiveness of that advertising.

Personal Information you provide may be converted into non-personal information in order to link other available data about you, including linking the various devices you may use. To opt-out of the use of this information to tailor the ads you are shown, you can use the “Limit Ad Tracking” settings on your mobile device. You will continue to see ads, but they will not be selected based on your activity across unrelated web sites or apps. Verve does not currently change its practices with regard to Do Not Track settings, but offers the options described in this policy. Please see www.allaboutdnt.org for a further description of your options.

Sensitive Information

When we create categories to serve ads based on your activity across different web sites or apps, we restrict the use of categories that we deem sensitive based on local law or applicable industry codes.

Retention

We retain ad serving data that is linked to an individual user for as long as needed to support our business needs for ad-delivery, reporting and auditing and no longer that 18 months, after which such data is deleted or minimized by having unique user level identifiers removed.

YOUR PERSONAL INFORMATION MAY BE PROCESSED BY US IN THE COUNTRY WHERE IT WAS COLLECTED AS WELL AS OTHER COUNTRIES (INCLUDING THE UNITED STATES) WHERE LAWS REGARDING PROCESSING OF PERSONAL INFORMATION MAY BE LESS STRINGENT THAN THE LAWS IN YOUR COUNTRY. BY USING THE SERVICES AND PROVIDING ANY PERSONAL INFORMATION, YOU ARE CONSENTING TO THE TRANSFER OF DATA FROM YOUR COUNTRY TO A COUNTRY THAT HAS LESS STRINGENT LAWS, AND THE PROCESSING OF YOUR PERSONAL INFORMATION IN CONFORMANCE WITH THIS POLICY.

Third Parties

Verve does not share your Personal Information except as provided in this Privacy Policy. We may disclose certain Personal Information:

  • To third party contractors, agents, service providers and vendors who help us provide the Services, in which case we will take reasonable steps to ensure that these parties comply with confidentiality obligations and contractually require these parties only use the information as needed to provide services to us;
  • To third parties to whom you ask or have authorized us to send Personal Information;
  • To any subsidiary organizations, joint ventures, or other organizations under our control (collectively, “Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy;
  • If we believe in good faith that such disclosure is necessary to (a) resolve disputes, investigate problems, or enforce our Terms of Use; (b) comply with relevant laws or to respond to requests from law enforcement or other government officials relating to investigations or alleged illegal activity; or (c) protect and defend our rights or property or the rights and property of you or third parties; or
  • In connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy.

We may disclose Non-Personal Information to vendors, such as analytics companies and to other advertisers or ad networks.

Security

Verve employs reasonable practices to restrict access to Personal Information to employees, contractors and agents who need to know the information in order to operate, develop or improve our Services and to service our customers. We take all reasonable steps to ensure that these parties comply with confidentiality obligations and do not use such information for any purpose other than providing such services to us.

Information collected at the Verve Corporate Web Site

The following describes information collection practices at this web site only.
For information about Verve’s advertising, data or technology services please see the Privacy Policy sections above.

Personal Information

Verve does not share your Personal Information except as provided in this Privacy Policy. We may disclose certain Personal Information:

  • To third party contractors, agents, service providers and vendors who help us provide the Services, in which case we will take reasonable steps to ensure that these parties comply with confidentiality obligations and contractually require these parties only use the information as needed to provide services to us;
  • To third parties to whom you ask or have authorized us to send Personal Information;
  • To any subsidiary organizations, joint ventures, or other organizations under our control (collectively, “Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy;
  • If we believe in good faith that such disclosure is necessary to (a) resolve disputes, investigate problems, or enforce our Terms of Use; (b) comply with relevant laws or to respond to requests from law enforcement or other government officials relating to investigations or alleged illegal activity; or (c) protect and defend our rights or property or the rights and property of you or third parties; or
  • In connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy.

How Personal Information is Controlled or Corrected

In the event you provide us with Personal Information, you can review, correct or update that information, or request its deletion, by emailing us at privacy@vervemobile.com.

Please keep in mind that if we did not collect any Personal Information from you we would have no reasonable way to associate your Personal Information with any other data and therefore would not be able to make any changes to such information. Assuming you do provide us with Personal Information that we retain, we may retain your Personal Information in conformance with our data retention policy, under which we may retain such information to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our Terms of Use, and take other actions otherwise permitted by law.

There may be residual Personal Information that remains within our databases, access logs, and other records. Please remember, however, if we have already disclosed some of your Personal Information to third parties, we cannot access that Personal Information any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures.

You may request that we delete, stop using or stop collecting precise location information through the Services or, in some cases, using your mobile device or application settings.

How Personal Information is Protected

We take reasonable security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include firewalls and encryption, internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems. You should take further precautions to protect personal data by safeguarding your user name and password and by limiting the use of shared computers. All Personal Information is stored on our secure servers in the United States of America.

Non-Personal Information

This site uses cookies, tracking pixels and other device identifiers to track usage of this site and to help deliver the site’s content.

Information Disclosed to Third Parties

This Privacy Policy addresses only our use and disclosure of information we collect from and/or about you. If you disclose information to others, including to third parties that may supply content or services to Verve, the use and disclosure restrictions contained in this Privacy Policy will not apply to any third party. We do not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable.

Changes to Privacy Policy

Verve is committed to continually examining and reviewing its privacy practices, and may make changes to its Privacy Policy. We will post any revisions to the policy at http://www.vervemobile.com/privacy.

Questions and Concerns:

If you have any questions or concerns about our privacy practices, you may contact us:

Verve Wireless, Inc.
5973 Avenida Encinas, Ste. 101
Carlsbad, CA 92008
Email: privacy@vervemobile.com

This Privacy Policy was last updated on April 1, 2014.