Gimbal Inc, End-user Privacy Policy
This is the Gimbal, Inc. (collectively “us” or “we” or “Gimbal”) End-User Privacy Policy (“Privacy Policy”). When an end-user (“you”) uses a third party application utilizing Gimbal technology or services, you will share some information with us. This Privacy Policy is written to explain what information we collect, how we use it, whom we share it with, and the choices that we give you to control, access, and update your information.
Gimbal has been awarded TRUSTe’s Privacy Seal. The TRUSTe Privacy Seal signifies that this Privacy Policy has been reviewed by TRUSTe for compliance with TRUSTe’s Mobile Privacy and TRUSTe Cloud program requirements. For questions regarding the Privacy Policy or practices, please contact Gimbal at privacy [at] gimbal [dot] com. TRUSTe may be contacted here.
Gimbal abides by the Safe Harbor framework set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information collected by organizations in the European Economic Area and Switzerland. To learn more about the Safe Harbor program, and to view Gimbal’s certification, please visit http://www.export.gov/safeharbor/.
The Safe Harbor program is due to be superseded by the EU Privacy Shield (http://www.privacytrust.com/privacyshield) later this year. Until such time, any information collected by Gimbal will be in compliance with the Safe Harbor or, as applicable, local laws and regulations.
Gimbal Technology
Certain third party applications utilize Gimbal technology to create a more personalized experience for their end-users. We may collect and use aggregate and anonymous information from those third party applications. Where we collect such information, our collection is dependent on the features that have been enabled by the particular third party mobile application and your agreement. Please note that third party mobile applications may choose to collect information outside of the enabled features. We are not responsible for the information collection and use policies of a particular third party application. We recommend you review the third party application’s privacy policy to better understand their practices.
Information We Collect
We collect information depending on which features are enabled by a third party application and where you agree or when information is provided to us by a third party.
Information you choose to give us. We may collect information you choose to provide a third party application which utilizes the Gimbal technology, such as when you designate a place in the third party application (e.g., “my gym”). Also, we may collect information if you participate in a survey, provide us feedback, or send us questions.
Information we get when you use our services. Where Bluetooth or the applicable features are enabled, we may periodically collect your location (e.g., latitude/longitude coordinates) and the time of day. Also, we may collect your advertising identifier, information about your device (e.g., make, model, and OS), app permissions info (e.g., deliver notifications, use location services, use Bluetooth, and other similar information), and the status of our Software Development Kit (“SDK”) (e.g., the version, whether it is activated/deactivated, and your use thereof).
Information we get from third parties. We may obtain information from other companies that are owned or operated by us, or any other third party sources, and combine that with the information we collect through our services.
How We Use Your Information
We have no direct relationship with the end-users of a third party application. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct related questions to the third party application. If requested to remove data, we will respond to your request within a reasonable timeframe.
We may use your information to support our products and services, as well as to create relevant new offerings. Our use includes where we:
• Respond to you when you contact us;
• Notify you of relevant events, promotions or other interesting content;
• Verify your identity and prevent fraud or other unauthorized or illegal activity;
• Provide us and the third party application with location-triggered information, such as when arrive at or leave a designated location;
• Monitor and analyze aggregate trends and usage;
• Create aggregate and anonymous audience segments for business purposes, as well as for other analytical purposes such as attribution, segmentation, de-duping, and re-targeting;
• Reference your comments or other feedback in our advertising, marketing, or promotional materials;
• And any other use that we describe at the point where we collect data or information with your consent.
How We Share Information
People use our services and products to create mobile engagement and more relevant experiences. We make this possible by sharing information in the following ways:
With our affiliates. We may share information within the Gimbal family of companies.
With third party data processors. We may share your information with agents, service providers, vendors, contractors, or affiliates who process the data on our behalf.
As required by law or as necessary to exercise our legal rights. We may share your information as required by law, such as to comply with a subpoena, bankruptcy proceeding, or similar legal process when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others. Also, we may also share your information in the interest of protecting or exercising our or others’ legal rights, e.g., without limitation, in connection with requests from law enforcement officials, to investigate fraud, to respond to a government request and in connection with court proceedings.
In the aggregate or after de-identification. We may also share with third parties, such as advertisers, aggregated or de-identified information that cannot reasonably be used to identify you.
In the event that Gimbal or substantially all of its assets are acquired, sold or subject to merger, your personal information may be one of the transferred assets. You will be notified via a prominent notice on the Gimbal Site of any change of ownership, uses of your personal information, and choices you may have regarding your personal information.
Information You Choose to Share with Third Parties
Our services may include third party links, integrations, or a co-branded or third-party-branded service that’s being provided jointly with or by another company. By going to those links, using the third party integration, or using a co-branded or third party-branded service, you may be providing information (including personal information) directly to the third party, us, or both. You acknowledge and agree that we are not responsible for how those third parties collect or use your information. We encourage you to review the privacy policies of every third party website or service that you visit or use, including those third parties you interact with through our services.
How Long We Keep Your Content
We retain information for only as long as it is necessary to:
• Provide products and services to you and others;
• Perform or fulfill our contractual obligations;
• Comply with our legal obligations;
• Resolve disputes; and
• Enforce our agreements.
By default, we store information on your device for up to sixty days and on our servers for up to two years. You may shorten these time periods by selecting the delete option in the Privacy Controls center in Gimbal.
Your Choices & Privacy Protections
Resetting Your Data ID. You may reset the unique ID randomly generated by Gimbal servers for each install of the Software on the device by selecting that option in the third party application settings. Please note, however, resetting the unique ID does not affect the information that was previously shared with the third party application. Please refer to the privacy policies of the third party application to better understand their privacy practices.
Safeguarding Your Data. To protect your privacy, we limit the amount of data that is sent to our servers. We take reasonable safeguards to help protect your personal information that we store on your device and that we transmit to our servers. If you have any questions about the security of your personal information, you may contact us at privacy@gimbal.com.
Transferring Your Data Across Borders. We may transfer your personal information outside your country of residence to countries or jurisdictions where we have facilities or to engage third parties to provide services to us for the purposes outlined in this Privacy Policy. Information collected within the European Economic Area (“EEA”) may, for example, be transferred to countries outside of the EEA. Such countries may not have the same level of data protection as within your country. If we do make such a transfer, we will take appropriate steps to ensure your personal information is protected.
Information of Minors
We do not knowingly solicit or collect personal information from or about children under 13 years of age, and we do not knowingly market Gimbal products or services to children.
California’s “Shine the Light” Law
We acknowledge that California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year. Without your consent, we do not distribute your personal information to outside parties for their direct marketing, or any other purpose, except as provided for in this Privacy Policy.
Safe Harbor Dispute Resolution.
As part of Gimbal’s participation in the Safe Harbor program, Gimbal will resolve disputes you have with Gimbal in connection with Gimbal’s practices and policies through TRUSTe. You may contact TRUSTe through their website.
Changes to This Privacy Policy
Gimbal may change this Privacy Policy from time to time. Gimbal encourages you to periodically review this page for the latest information on Gimbal privacy practices. You will be deemed to have acknowledged and accepted any such changes by your continued use of the Gimbal Site after the effective date. As required by law, Gimbal will provide you with notice prior to any changes becoming effective.
Contact Us.
Please feel free to contact Gimbal with any comments, questions, or suggestions you may have regarding the privacy practices. You may contact Gimbal by email at privacy@gimbal.com, or writing to Gimbal at:
Gimbal, Inc.
Attn: General Counsel
11010 Roselle St, Ste 150
San Diego, California, USA, 92121
Effective. June 28, 2016