Website Privacy Policy

Effective: 13 October 2021

This Site Privacy Policy applies to Near’s website.

For information on: (i) how Near collects, uses and shares consumer data with respect to Near’s products and services; and (ii) consumer data protection rights, please see Near’s Business Privacy Policy and Mobile App Products Privacy Policy.

1. Policy coverage

This Site Privacy Policy describes how Near (also referred to as “we”, “us”, or “our”) collects, uses and shares information received from you when you visit www.near.co. Our Site is primarily designed to provide information to our customers and partners, which are typically businesses.

This Site Privacy Policy lays down applicable data protection rights of the site visitors and their right to object to processing their information.

In order to use our Site, you authorise Near to transfer your personal information across national borders and to other countries where Near and its partners operate, including the United States. The privacy protections and rights of authorities to access your information in these countries may not be equivalent to those in your country. We will only transfer your personal information to these countries, where permitted to do so by law and we will take steps intended to ensure that your personal information continues to receive appropriate protections.

2. Information collected through the Site

(A) Near Site

When you visit our Site or contact us to know more information about our products and services, Near collects information that identifies you or which is associated with your device or browser.

Information Purpose
Contact Details
  • Name
  • E-mail address
  • Company name
  • Phone number
  • Country
  • To respond to your queries when you contact us.
  • To provide more information on our products and services when you contact us.
  • Send marketing emails.
Device/Browser Information
  • Browser type version and language;
  • Operating system;
  • Referrer URL;
  • Near URL’s that are accessed; and
  • Internet protocol (IP) address.
  • To determine locality of user in order to set the right language for the user.
  • To provide a smooth experience while accessing our Site.
  • We do not collect the whole IP but a part of it which is directly related to the user for better user experience.

(B) Near Emails

We may send marketing emails to you. Emails received from Near may include a technology (called a web beacon (elaborated below)) that informs Near whether you received or opened the email or clicked a link in the email. If you would like to discontinue receiving marketing email from us, you may update your email preferences by using the “unsubscribe” link found in emails or by contacting us at privacy@near.com. If you are in European Economic Area (EEA), United Kingdom (UK), Switzerland or California you can also exercise the rights described in the section below under Individual users rights.

Web beacons (or “tags”) are bits of programming code included in web pages, emails and ads that notify Near (or the companies that help us to run our business) when those web pages, emails or ads have been viewed or clicked. Embedded scripts are bits of programming code included within some of our web pages that measure how you use those web pages, such as which links you click. We use this information to improve our websites. You may be able to turn off scripting functionality, such as JavaScript, within your browser (please refer to your browser's help function). Note that if you disable scripting functionality, some Near websites may not function properly.

(C) Usage Information

Our Site uses Google Analytics, a web analysis service of Google, Inc. Google Analytics employs cookies that are stored on your computer in order to facilitate an analysis of your use of the Website. The information generated by these cookies, such as time, place and frequency of your visits to our Website, including your IP address, is transmitted to Google’s location in the US and stored there.

3. Use of information collected by Near and the legal basis for these uses

(A) Purpose

Near uses the information for the following purposes:

  • Responding to your inquiry;
  • Sending you information about Near products and services;
  • Sending you marketing emails; and
  • Investigating and responding to any comments or complaints that you may send us.

(B) Consent

Where required, when you give Near your consent, we place cookies and use similar technologies on our Site, and in email communications, in accordance with our Cookie Policy.

4. Cookies

A cookie is a text file containing an identification number which, when the Site is used, is transmitted to the user’s computer together with the other data actually requested and stored there. The file is kept there for later access and serves to authenticate the user. Since cookies are simple files and not executable programs, they do not pose any danger to the computer. You can choose to disable cookies, it may limit your use of certain features or functions on our website or service. For more information about cookies, please visit https://www.allaboutcookies.org/.

5. Sharing of personal information

(A) Sharing with Near’s Group Companies

Near will share your personal information within the Near group of companies for the purpose identified above.

If you are using an email address that is associated with a business domain (e.g., yourname@businessname.com) to access the Site, we may provide your personal information to that business.

(B) Sharing with Service Providers

Near will share your personal information with companies that help us run our business by processing personal information on behalf of Near for the purposes identified above. Such companies include Amazon Web Services and Google Analytics.

(C) Sharing with Government, Law Enforcement Agencies or Regulatory Bodies

Near will share your personal information with applicable government, legal agencies or regulatory bodies in order to comply with applicable laws and investigations or to respond to a court order, judicial or other government subpoena.

(D) Sharing with Acquiror or Merger Entity

Near may transfer information, including any personal information, to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change. If Near is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

(E) Other Information Sharing

Near may share your personal information with your consent or if it believes that it will protect Near, you or any other person or third party or to enforce any legal rights.

6. Interest based advertising opt-out

You may opt-out of interest-based advertising from Near, by clicking here.

7. Links to third-party websites, applications and services

The Site provides links to third-party websites, applications, including social media pages, integrated social media tools or “plug-ins,” such as social networking tools. We do not own or have any control over the privacy practices of these third parties, and they are not covered by this Site Privacy Policy.

If you decide to use any of the links available on the Site, you should review their privacy notices to learn about their data practices. If you use these tools to share personal information or you otherwise interact with these features, those companies may collect information about you and may use and share such information in accordance with your account settings, including by sharing such information with us and the general public.

8. Security of personal information

The security of your information is important to us. Near has implemented reasonable security measures to protect the information in our care, both during transmission and once it is received. This includes but is not limited to the use of firewalls and encryption. No method of transmission over the Internet or method of electronic storage is 100% secure; therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security.

9. Storage duration

Once collected, Near will store your contact information, site usage information for no longer than 12 months from the time of collection, or such shorter period as required by law. However, we may retain your information beyond this time if required by law.

10. Accessing your information

If you provide your personal information and you wish to update, correct, or delete inaccuracies within that information, you may contact us as at privacy@near.com. We will respond to your request within a reasonable timeframe.

11. Information relating to children

Near does not knowingly collect personal information from anyone under the age of 13 through the Site. If you are below the age of 13 years, you should not use this Site or provide any information about you to us. If we are made aware that we have received personal information from someone under 13 years of age, we will use reasonable efforts to immediately remove that information from our records.

12. Individual users rights

(A) In EEA, UK or Switzerland

  • If you are a resident in the European Economic Area and want to find out more about your data protection rights, please see our separate section called “EU Privacy Notice – GDPR

(B) In California

  • For personal information access, opt out and deletion requests with respect to any personal information processed by Near, and for personal data of data subjects for residents of EU, UK and Switzerland, you can follow the instructions on our Consumer Choices page. Please note that we will need your Mobile Ad ID in order to identify your device in our systems.
  • While CCPA only covers California residents, we will voluntarily extend its core rights for people to control their data to all of our users across the World, not just those who live in California.

13. Changes to this Privacy Policy

This Privacy Policy is subject to change from time to time. We encourage you to periodically review this page for the latest information on our privacy practices.

14. Contact information

For questions or concerns relating to privacy, please email us at privacy@near.com or write to our Data Protection Officer or send physical mail to Near Pte. Ltd.:

Data Protection Officer
Prof. Dr. Christoph Bauer
CEO
ePrivacy GmbH
Große Bleichen 21
20354 Hamburg
Germany

Near Pte. Ltd.
3 Temasek Avenue,
Level 18-01, Centennial Tower,
Singapore 039190

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S. based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Business Privacy Policy

Effective: 13 October 2021

This Privacy Policy describes how the mobile advertising and data intelligence services (the “Services”) of Near Pte. Ltd. (“Near” “We” “Us”) collect, store, and use the information we collect from our partners about consumers.

For information on privacy practices for the website owned by Near, please see Site Privacy Policy and if you are interested in the privacy practices for the mobile app products owned by Near, please visit Mobile App Products Privacy Policy.

1. What Services does Near provide?

We provide Services which includes advertising optimization, data intelligence, analytics, visualization and measurement tools. Our technology uses various information collected to provide useful insights, reports, analytics and research information to our customers and partners.

Our customers and partners include publishers, advertisers, data partners, and third-party ad exchanges.

2. What information does Near collect about Users?

When individuals (“Users” or “you”) visit: (i) an App that uses the SDK of our partners; or (ii) a website that uses javascript tag of Near, Near or its partners will collect certain information about the Users which may include personal data or User’s device data. The information we collect are listed below along with the purpose for which this information is used.

Data Purpose
1. Device information such as:
  • Identifiers for advertising (IDFAs) for IOS and Android ad ids for Android (together known as “MAIDs”),
  • IP addresses
  • approximate location data,
  • Browser type
  • Device type,
  • Time stamp,
  • Operating system information and version (e.g. iOS ver 10), and
  • Language preference.

For providing advertising and data intelligence services.

  • Gender
  • Age
  • Hashed email address (HEMs)
  • Appgraph data
  • Impressions

3. How does Near collect or receive User data?

(A) Through Partners

  • Partner SDKs used in publisher apps. Near receives MAIDs, other User data from its partners that utilize their SDKs in various publisher apps.
  • API Connectors. Near’s APIs are connected to various partners APIs. Such partners share MAIDs, IP, location and other User data through these APIs.
  • Ad Network Providers. We receive MAIDs and other information about Users from the mobile ad network providers for targeted advertising purpose. For advertising targeted to Users in the EU, UK, and Switzerland, Near is an approved status vendor and participates in the IAB Europe Transparency and Consent Framework (see more at https://advertisingconsent.eu/about/). Legally sufficient consent is obtained using this framework from those publishers whose Apps utilize the framework. In addition, Users have the ability to withdraw consent at any time by contacting the publisher of the relevant App or Site and checking your privacy settings on your devices and with the Apps and Sites you visit from time to time.
  • Website Publisher Partner. Near receives device information and impressions from its website publisher partner for providing data intelligence services. Our Services may use persistent cookie-like tools such as javascript tag that enable us to measure the effectiveness of the ads served, and for data intelligence about the activities of Users on websites. Users are free to set their consents on the settings of their browser, operating system and device to de-activate the ability to identify their device persistently. Please refer to these settings for more information on how to disable the browser or operating system from receiving cookies and controlling your preferences, including to disallow sharing of device level information or to disable geolocation access.

While receiving data through its partners, Near does not directly interact with the Users. Our partners obtain consent from the Users and share the valid consent with us. Near only works with partners that agree to notify and seek consent of the Users informing them that their data will be captured and shared with third parties. Near only stores data that comes with a proof of valid consent from its partners.

4. How does Near use User information?

  • Our data intelligence services involve best estimate data information and reporting to customers. We use our proprietary tools to transform MAIDs collected, along with approximate geolocation information and other User data, into actionable insights for our customers. Our technology enables us to provide our customers with trend and statistical analyses, such as identifying patterns that will enhance the relevance of ads, providing advertisements to certain types of audiences, identifying and optimizing trade areas and business locations, and for helping our customers make informed business decisions about consumer behavior with trend and movement information. We provide actionable insights, patterns and commonalities to enable our customers understand trends, and evaluate the products and services they offer, such as enabling engagement with audience and enhancing customer experience for an ecommerce website or app.
  • The MAIDs we collect are stored in our systems for advertising purposes only. Much of the other information collected is further anonymized into aggregated files and use of data points without unique identifiers or only with a hashed identifier. The geolocation we collect is also randomly jittered as another step in making the data less personal. We sell cluster of information which includes hashed device identifiers with jittered geolocation information to customers that utilize our data intelligence services. This information is used in a number of ways to offer such customers, information about business trends, reports, patterns.
  • A part of the technology retains MAIDs to cater to our US specific customer’s request for targeted advertising, measurement and matching. This data is stored separately from the anonymized data.
  • Near provides audience curation for advertising, understanding trends etc., but does not create data segments that are based on sensitive personal information (for example, religion or credit worthiness). However, We may create health-related segments such as an inferred interest in diet and wellness, but not sensitive health data such as medical conditions or diseases. All of our customers who subscribe to our Services are required to conform to the applicable privacy laws and regulations as well as our contractual requirements. Near prohibits the use of its Services by others for (a) employment, credit or health care eligibility; (b) insurance eligibility, underwriting, or pricing; (c) unlawful tracking or surveillance of individuals or for generating personally identifiable information.
  • Our Services also include advertising services that allow us to help our advertising and publishing customers provide more relevant advertising and content on the Apps on our Network. In general, we use the User information collected from partners to enhance our advertising services by providing ad content that is more closely related to Users interests. For example, the information is used to create audiences that are grouped together based on shared preferences (e.g., Sports Fans, car enthusiasts, movie goers, travellers) and to measure the effectiveness of ad campaigns. Data used to create online audiences is de-identified, helping ensure that neither the ad server nor our cookies contain personal data. We may assign a Near ID in our internal systems for your browser, computer or mobile device when we serve an ad to it or we identify it on a publisher partner’s website or mobile app. The Near ID and other information collected via the Services can also help our advertising customers measure the effectiveness of advertisements delivered via the Services. They enable the Services to determine within a reasonable level of confidence that a computer or device is the same as one with which the Services has previously interacted. For instance, the Services can determine that a computer or device to which we served an ad on Monday may be the same computer or device for which we observed a purchase on Tuesday. In other words, in such cases we are able to infer that a device (e.g. your computer) and another device (e.g. your smartphone) are used by the same owner. Where we are able to make such inferences, we may use this information to deliver targeted ads across multiple computers or devices. This is sometimes referred to as cross-device advertising.

5. What are the basis for processing User information?

(A) Near may collect your PI on the basis of the following:

  • your consent;
  • the need to perform a contract;
  • our legitimate interests or those of a third-party;
  • the need to comply with the laws; or
  • any other ground, as required or permitted by law.

6. Who do we share User Information with and purpose for sharing this information?

Near shares derived intelligence over data collected with customers, partners third-party service providers, affiliates of Group Companies, prospective acquirer, for the following purposes:

(A) Customers and partners

When customers need MAIDs for targeted advertising, measurements and matching, we sell unhashed MAIDs only for this purpose. We ensure our customers do not use MAIDs for any other purpose except for the purposes mentioned immediately above. All other information is sold in an aggregate and anonymized manner which cannot identify you. It is essentially to provide segments, trends, patterns, reports and insights to the customers.

(B) Third-party service Providers

  • When customers (businesses not consumers) subscribe to our Services, the order process may request a credit card transaction. Order information is encrypted when it is transmitted for credit card processing to the credit card services provider and when returned to us. Encryption is a process by which we use software to scramble information in transit. We use a third party service provider to process payments for our Services, so your credit card information is not collected and retained by Us.
  • with those entities that help us make the Services available and functional, like technical agents, payment processing vendors, other subcontractors, and our affiliates and consultants under contract and with safeguards. These functions include, for example, web site hosting, maintenance, data analysis, customer support, email delivery services, infrastructure services, technical agents, analytics and metrics services. These third parties will be restricted in the way they can use PI and will need to keep your information confidential and secure.

(C) Affiliates of Group Companies

Near will share your information within the Near group of companies to ensure Near is able to provide Services to its customers.

(D) Government, Law Enforcement Agencies or Regulatory Bodies

Near will share your information with applicable government, legal agencies or regulatory bodies in order to comply with applicable laws and investigations or to respond to a court order, judicial or other government subpoena.

(E) Acquiror or Merger Entity

Near may transfer information, including any personal data, to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change.

(F) Other

Near may share your personal data with your consent or if it believes that it will protect Near, you or any other person or third party or to enforce any legal rights.

7. Security

The security of your information is important to us. Near has implemented reasonable security measures to protect the information in our care, both during transmission and once it is received. This includes but is not limited to the use of firewalls and encryption. No method of transmission over the Internet or method of electronic storage is 100% secure; therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security.

8. Do you collect information on children?

Near does not knowingly collect personal data from anyone under the age of 13 through the Site. If you believe your child has provided Near with PI, such as by registering at one of our Apps without parental consent, and you would like to have the data removed, please contact us using the contact information below.

9. How long is User data stored?

For personal data, we keep your data only for as long as we need it for our legitimate business purposes. For example, when we collect information about your interaction with an advertisement served to you, we retain that information for 180 days and then delete it. Other information, like device ids, we retain for our ongoing Services. We will retain your information for as long as the Services are active and after that, for a period which enables us to handle or respond to any complaints, queries or concerns relating to the Services. We will periodically review the personal data we hold and delete it securely, or in some cases anonymize it, when there is no longer a legal, business, or consumer need for it to be retained.

10. What rights do Users have?

If you provide your PI and you wish to update, correct, or delete inaccuracies within that information, you may contact us as at privacy@near.com. We will respond to your request within a reasonable timeframe. Please refer to the Consumer Choices page for more details.

(A) IN EEA, UK or Switzerland

  • If you are a resident in the European Economic Area and want to find out more about your data protection rights, please see our separate section called “EU Privacy Notice – GDPR

(B) In California

  • For personal information access, opt out and deletion requests with respect to any personal information processed by Near, and for personal data of data subjects for residents of EU, UK and Switzerland, you can follow the instructions on our Consumer Choices page. Please note that we will need your Mobile Ad ID in order to identify your device in our systems.
  • While CCPA only covers California residents, we will voluntarily extend its core rights for people to control their data to all of our users across the World, not just those who live in California.

11. Changes to this Privacy Policy

This Privacy Policy is subject to change from time to time. We encourage you to periodically review this page for the latest information on our privacy practices.

12. Dispute Resolution

This Privacy Policy shall be governed by and construed in accordance with the laws of Singapore applicable to agreements made and performed in Singapore, excluding the application of the conflict of law provisions. You agree that any action or suit brought by a party to enforce or adjudicate your rights under this Agreement shall be brought in the courts located in Singapore. This Privacy Policy is subject to our Terms of Service.

13. Contact Information

For questions or concerns relating to privacy, please email us at privacy@near.com or write to our Data Protection Officer or send physical mail to Near Pte. Ltd.:

Data Protection Officer
Prof. Dr. Christoph Bauer
CEO
ePrivacy GmbH
Große Bleichen 21
20354 Hamburg
Germany

Near Pte. Ltd.
3 Temasek Avenue,
Level 18-01, Centennial Tower,
Singapore 039190

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S. based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Mobile App Products Privacy Policy

Effective: 13 October 2021

This Privacy Policy describes how Near Pte. Ltd. (“Near” “we” or “us”) collects, stores and uses information about users of our websites (“Sites”) and mobile applications (“Apps”) owned by Near Pte. Ltd. (collectively, the “Products”). By using our Products, you agree to Near’s collection, storage, use and disclosure of information as described in this Privacy Policy. If you disagree with anything in this Privacy Policy, please do not install or use Our Products.

Background

Our Products support users’ experience with Twitter including the social apps Echofon, UberSocial, and Plume. To use these Apps, users (“Users”) need to log in in using their Twitter credentials.

WHAT INFORMATION IS COLLECTED

We collect the following types of information from our Users:

  • Information You Provide: When you set up your account, provide us with an email, or share information with us in any other way, such as a customer support request, we collect and store the information you share. This will include your Twitter handle, but not your password which is retained by Twitter. You do not have to share information with us, but without it you may not be able to access certain content or features of the Products.
  • Automatic Collection: Like many technology providers, we use common internet technologies such as cookies on Sites and persistent tools on Apps to keep track of users’ interactions with the Products. These tools will collect general device and browser information, including device type and model, browser type and version, app type and versions, as well as information related to your use of the Products. We also contract with third party providers who use similar tracking tags on the Products via SDKs, to collect information about your use of the Products, for advertising, analytics, and measurement purposes. More about this is discussed below.
  • Publicly Posted: If you post information on public areas via the Products (or elsewhere on the internet), that information is public and may be collected, stored and used by anyone, including us. We use a Twitter API to pull up your posts and timeline information; such information is stored by Twitter and is not stored by us.
  • Use of Social Media Applications: The Products utilize certain API “feeds” or other mechanisms provided by third parties, notably Twitter (“Third Party Apps”), to access your accounts as authorized by you when you use of the Products. Those Third Party Apps may share information about you with us, depending upon the privacy settings you have set within your account for such Third Party Apps. The Third Party App settings enabled by you do not allow us to access content, data or information not authorized by those privacy settings. Please refer to the privacy settings in your Third Party Apps account to manage your public profile and other aspects of your account with those Third Party Apps.
  • Mobile Location Information: If you consent to allow access to your geo location on the Products, and the Products are location enabled, we will collect and store information related to your mobile device location including over time to help provide a better experience with our Products and in connection with advertising, analytics, and measurement. Some functional use of the Products may be dependent on the data related to geolocation information (such as when you post a tweet from or about a location). If the settings on your device allow us to receive location information, we may also associate location information with other information we have about you. You are always free to turn off geolocation on your device (or limit it to certain Apps).

Some of this information may identify a particular device and may be “personal information” under some jurisdictions. Personal Information, as the term used in the United States, or Personal Data as referred to pursuant to the European Directives 95/46/EC and 2002/58/EC (EU General Data Protection Regulations Legislation, also known as “GDPR”) (hereinafter “PI”) has different definitions. Different regulations around the world may use different terminology and apply a different description of what information is considered personal information, so we encourage you to visit our jurisdictional specific pages as applicable (i.e. GDPR Notice).

The information we collect from devices that may be considered PI are:

  • your Twitter handle
  • mobile advertising device IDs (MAIDs): these are IDFAs for iOS, and Android Ad IDs for Android
  • Information about a User’s activities or actions on the Products and interaction with advertising that run on the Products (session start/stop time, and advertising click-stream information)
  • IP addresses and general location data that can be extrapolated from an IP address level (city or postal code)
  • Latitude and longitude geolocation information if a User has provided consent from the relevant Product and enabled the mobile device to share location information. You are always free to turn off geolocation (or limit it to certain mobile applications) or to adjust your advertising settings on your device.

For clarity, and without limiting the above, we do not collect information that directly identifies a natural person, including the following information, among other information: names, email addresses, cell phone or home phone numbers, login passwords, social security, drivers licenses. We also do not collect financial or other sensitive information.

Advertising on the Products

The Products display advertisements (“Ads”) which are delivered by Near’s services and through third party providers. When Ads are served, information regarding interaction with the Ads shown to you is collected by the third party advertising exchange partners and us. The Ads that are served on the Products include targeted, behavioral advertising based upon information compiled about users to provide more relevant advertising content. Near and third parties operating the ad serving platforms we use, collect and utilize interest, contextual, demographic, geolocation information, and device-related information (i.e. device ID and browser type, date and time stamps) and information related to Ads served (such as preferences, content viewed, clicks and views) in connection with delivering and measuring advertising. This data is used to help choose which Ads to deliver and to enhance our advertising and analytics capabilities, as well as to offer analytics measurement and data enhancement services to our partners for their marketing and advertising purposes. When the Products are location enabled, and you have consented to enabling access to geolocation data on the Products, Near will collect and process geolocation data over time and use this data in connection with the advertising, measurement, and attribution services as described herein. To the extent Near makes available geolocation to third parties in accordance with this Privacy Policy, it will be provided without identifying you personally.

The Products are enabled with tools to support the services of third parties performing advertising and analytics on the Products. The third party service provider tools implemented on our Products are for the purposes of: advertising services, analytics and crash reporting services, Emoji (in UberSocial/Android and UberSocial/iPhone), Facebook (to enable cross-posting and showing timelines); an Android-file logger (to allow Users to share app logs with us). To enable these services, those tools will collect and transmit devices ID, device-related and application-related information to those providers.

HOW INFORMATION WE COLLECT IS USED

We use the information we collect for a variety of business purposes in connection with the Products, which include the following purposes:

  • Providing Our Services: Generally we use the information we collect about Users to inform about our products (including advertising) as described in this Policy and to fulfill your requests and validate your User rights; contact and communicate with you; and as otherwise described in this Policy.
  • Serving Ads: To allow us to offer advertising inventory in the Products and to fill that inventory with relevant ads.
  • Performance Analytics: To analyze ad performance, such as tracking views of ads, as well as click-through rates to websites or app stores and/or installs of apps that have been advertised.
  • Service Usage and Support: To calculate usage levels, to help diagnose server problems, and administer the Products.
  • Use for Our Services Business (as described in our Business Services Privacy Policy)
  • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside a User’s country of residence; (b) to comply with subpoenas, warrants, or other legal process; (c) to respond to requests from public and government authorities including public and government authorities outside an User’s country of residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, Users, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

WHERE WE SHARE INFORMATION

  • Anonymous/Aggregated Information. Anonymous or aggregated information that does not identify you personally, like usage and metrics information, may be shared with others, including partners, developers, potential investors, marketers, and business partners. Anonymous information helps us understand trends and user needs so that we can better design new products and services and refine existing products and services to serve our customers better.

PI May Be Shared As Follows:

  • during due diligence or in preparation for or after a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization or liquidation. If Near or its assets is purchased, all associated data and information will be transferred.
  • with those entities who are helping us make the Services available and functional under contract and with safeguards. These include third-party vendors, technical agents, subcontractors, and our affiliates and consultants who assist us in performing functions to operate our Services. These functions include, for example, website hosting, maintenance, data analysis, customer support, infrastructure services, technical agents, analytics and metrics services. These third parties will be contractually restricted in the way they can use PI.
  • As in any transaction, if you provide your credit card information for purchases on Product, our credit card processor and your credit card company will be provided with all relevant information about us, item(s) purchased, cost and other information necessary to process the transaction. We use a third party service provider to process payments made on our Sites, so your credit card information is not collected and retained by us.
  • when permitted or required by law or where we believe such action is necessary in order to protect or defend our interests or the interests of our users or business partners.
  • We may disclose PI to the extent required by law, or if we have a good-faith belief that we need to disclose it in order to comply with official investigations or legal proceedings (whether initiated by governmental/law enforcement officials, or private parties). If we have to disclose PI to governmental/law enforcement officials, we may not be able to ensure that those officials will maintain the privacy and security of PI.

WHAT ARE MY CONSUMER CHOICE/DATA PROTECTION RIGHTS/OPT OUT

For personal information access, opt out and deletion requests with respect to any PI processed by Near, and for personal data of Data Subjects for residents of EU, UK and Switzerland, you can follow the instructions on our Consumer Choices page. Please note that we will need your Mobile Ad ID in order to identify your device in our systems.

While CCPA only covers California residents, we will voluntarily extend its core rights for people to control their data to all of our users across the United States, not just those who live in California.

EUROPEAN UNION, UK AND SWITZERLAND ADDITIONAL NOTICE

If you are a resident in the European Economic Area and want to find out more about your data protection rights, please see our separate section called “EU Privacy Notice – GDPR

SECURITY

Information that Near collects is stored on servers that Near manages, using standard security procedures and practices appropriate to the nature of the information. Please be aware that no data transmission over the Internet or information contained in our servers can be guaranteed to be 100% secure. As a result, Near cannot guarantee or warrant the security of any information you transmit on or through the Products and you do so at your own risk.

CHILDREN’S PRIVACY

The Products not intended for children under age 13 (or up to age 16 in certain countries), or for anyone under age 18 without involvement of a parent or guardian. The Products includes unmonitored content posted by users and sourced from other third parties and as you can imagine, such content may be unsuitable for children. We do not knowingly collect or distribute information from or about children under 13 (or up to age 16 in certain countries).

CHANGES TO PRIVACY POLICY

Near reserves the right to change this Privacy Policy at any time, and will do so by posting changes to this Privacy Policy. The new Privacy Policy will apply to all Users of the Products and will replace any prior Privacy Policies that are inconsistent.

DISPUTE RESOLUTION

This Privacy Policy shall be governed by and construed in accordance with the laws of Singapore applicable to agreements made and performed in Singapore, excluding the application of the conflict of law provisions. You agree that any action or suit brought by a party to enforce or adjudicate your rights under this Agreement shall be brought in the courts located in Singapore. This Privacy Policy is subject to our Terms of Service.

WHO WE ARE. CONTACT US

For questions or concerns relating to privacy, please email us at privacy@near.com or write to our Data Protection Officer or send physical mail to Near Pte. Ltd.:

Data Protection Officer
Prof. Dr. Christoph Bauer
CEO
ePrivacy GmbH
Große Bleichen 21
20354 Hamburg
Germany

Near Pte. Ltd.
3 Temasek Avenue,
Level 18-01, Centennial Tower,
Singapore 039190

Privacy Notice - California CCPA

Effective on: 13 October 2021

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of Near Pte. Ltd. (collectively, “we,” “us,” or “our”) and applies solely to consumers who reside in the State of California (“consumers” or “you”). This Notice does not apply to any employees. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Terms defined in the CCPA have the same meaning when used in this notice.

CCPA

Under the CCPA, Personal Information is defined to include all of the following categories:

Category Examples
Identifiers. A unique personal identifier, Internet Protocol address, email address, account name, or other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Social Security number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, gender, pregnancy or related medical conditions, sexual orientation, veteran or military status, genetic information (including familial genetic information).
Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Browsing history Internet activity information including browsing history, search history, interaction with a website or with advertisements.
Geolocation data. Physical location or movements.
Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information.

Personal Information under the CCPA does not include publicly available information from government records; de-identified or aggregated consumer information or information excluded from the CCPA’s scope, like health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA).

Personal Information We Collect

We collect the following categories of Personal Information under CCPA from consumers within the last twelve months:

For Personal Information
Advertising and Business Intelligence Services

Device information such as mobile advertising device ids (MAIDs), ip addresses, and browser typeGeolocation data (if enabled) associated with a device id. such as latitude-longitude, GPS source, postal code, and country code, gender, age.

Interaction with advertisements including advertising click-stream data

Our Mobile Apps

Your Twitter handleMobile advertising device ids (MAIDs), ip addresses, and location data (if enabled) associated with a device id;

Browsing history with Apps and interaction with advertisements including advertising click-stream data

Our Websites Your ip address, your interactions with the Sites, operating system, referrer URL

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from Products (mobile apps) and our SDKs
  • Indirectly from our demand and supply partners of mobile advertising networks and from select data partners.
  • Directly and indirectly from activity on our website. For example, from submissions through our website portal or website usage details collected automatically.

Use of Personal Information

As discussed more fully in our Privacy Policies, most of the information we collect and use is de-identified and aggregated information, such as de-identified categories of app use and jittered geolocation information associated with a de-identified device id. We also provide partners with de-identified device id information, except in the case when the actual device id is needed, such as for targeted advertising and for matching and measurement of advertising. De-identified and aggregated information is not Personal Information, and we use such information in a number of ways for our business intelligence services as we discuss in our Privacy Policy, including for marketing and targeted advertising and data analytics.

We do not use your twitter handle other than to authenticate your use on our Twitter-based Apps.

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.

Information Request

You have the right to request that we disclose certain information about our collection and use of your Personal Information about you over the past 12 months. To provide this information we need your mobile advertising device id (which is a unique id number assigned to each device). We ask you to complete a form and then follow the instructions to provide us with a legible image of your mobile advertising device id. Once we receive and confirm your consumer request, we will disclose to you:

  • The categories of Personal Information we collected about you.
  • The categories of sources for the Personal Information we collected about you.
  • Our business or commercial purpose for collecting or selling that Personal Information.
  • The categories of third parties with whom we share that Personal Information.
  • If we sold or disclosed your Personal Information for a business purpose, we will also identify the categories of Personal Information we shared by such sale.

Access Right

CCPA provides consumers with rights to request access of the Personal Information about them when the consumer can verify that they are the rightful owner of the information requested. We need your mobile ad id in order to identify any device in our systems but we don’t have a way to confirm that the device mobile ad id actually belongs to the particular person making the request. That’s because we do not collect the information that would match the device id to the actual owner (such as a name or account information) to allows us to confirm that the consumer requesting the information is the same consumer that owns the device. It would require us to actually collect more Personal Information to try to verify who the device owner is, such as requesting a full name, address, and receipt of purchase of the device. Additionally we want to avoid the potential risk of providing a requestor who provides a mobile ad id with the Personal Information that belongs to another individual. For example, a requestor can take a snapshot of the device id of his/her friend and request her Personal Information without her consent. Accordingly, in a matter of caution, we are not able to provide the particular file associated with any particular mobile advertising device id. If you are uncomfortable with our having any Personal Information about you, please send us a request to opt out or to delete your information.

Opt Out Of Sales And Deletion Request Rights

You have the right to request that we opt out your Personal Information from any sales. You also have the right to request that we delete your Personal Information. Once we receive and confirm your verifiable consumer request, we will honor your request (and direct our service providers to as well).

We may deny your deletion request if we cannot verify the device id or it meets one of the exemptions under CCPA. We will also retain a copy of our records related to processing your request.

Exercising Access, Opt Out, And Deletion Rights

To exercise the rights described above, please visit our Consumer Choices pages. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. We cannot respond to your request if we cannot verify your mobile device identity to confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in the request to process the request and to a retain a record of the request.

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 do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or unfounded.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.

Changes to This Notice

We reserve the right to amend this notice at our discretion and at any time. When we make changes to this privacy notice, we will post the update information on our website.

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.

GDPR Notice

PRIVACY NOTICE: EUROPEAN UNION, UK AND SWITZERLAND ADDITIONAL NOTICE

Effective on: 13 October 2021

This PRIVACY NOTICE FOR EUROPEAN UNION, UK AND SWITZERLAND RESIDENTS supplements the information contained in the Privacy Statements of Near Pte. Ltd. (“Near” or “We,”) and applies solely to data subjects who reside in those countries (“Data Subjects” or “you”). We adopt this notice to comply with pursuant to the European Directives 95/46/EC and 2002/58/EC (EU General Data Protection Regulations Legislation, also known as “GDPR”) and addresses data subjects whose Personal Data we may receive in the course of delivering our mobile advertising and business intelligence services (collectively, the “Services”). Terms defined herein shall have the same meaning as in the GDPR when used in this notice, except as otherwise noted herein.

Controllership

Within the scope of this Policy, we acts as a data controller for the Personal Data we process.

Basis of Processing

We may process your Personal Data on the basis of:

  • your consent;
  • the need to perform a contract;
  • our legitimate interests or those of a third party, such as our interest in marketing our Services;
  • the need to comply with the law; or
  • any other ground, as required or permitted by law.

Where we process your Personal Data based on your consent, you may withdraw it at any time. However, this will not affect the lawfulness of our processing before you withdrew your consent. It will also not affect processing performed on other lawful grounds.

How We Receive Personal Data

We may receive your Personal Data:

  • when you provide it directly to us as part of using our websites or mobile applications;
  • when you provide it directly to us as part of formation or fulfillment of a contract or as part of us delivering our Services;
  • from third party app publishers and advertising companies who collect your Personal Data through their web-based software applications;
  • when our service providers provide it to us; or
  • we purchase data from trusted third parties.

Categories of Personal Data

We may process the following types of Personal Data from Data Subjects:

For Personal Data
Advertising and Business Intelligence Services

Device information such as mobile advertising device ids (MAIDs), ip addresses, and browser typeGeolocation data (if enabled) associated with a device id. such as latitude-longitude, GPS source, postal code, and country code, gender, age

Interaction with advertisements including advertising click-stream data.

Our Mobile Apps

Your Twitter handleMobile advertising device ids (MAIDs), ip addresses, and location data (if enabled) associated with a device id;

Browsing history with Apps and interaction with advertisements including advertising click-stream data

Our Websites Your ip address; and your interaction with the Sites, operating system, referrer URL

Purposes of Processing

We may process your Personal Data for the purposes of:

  • providing the Services to our customers;
  • creating and updating data sets;
  • providing targeted advertising and content;
  • responding to your requests or questions; and
  • sending you email marketing communications about our business which we think may interest you.

Data Retention

For Personal Data , We keep your Personal Data only for as long as we need it for our legitimate business purposes. For example, when we collect information about your interaction with an advertisement served to you, we retain that information for the calendar quarter and then delete it. Other information, like device ids, we retain for our ongoing Services. We will retain your information for as long as the Services are active and after that, for a period which enables us to handle or respond to any complaints, queries or concerns relating to the Services. We will periodically review the Personal Data we hold and delete it securely, or in some cases anonymize it, when there is no longer a legal, business, or consumer need for it to be retained.

Sharing Personal Data with Third Parties

As discussed more fully in our Privacy Policies, most of the information we collect and use is de-identified and aggregated information, such as de-identified categories of app use and jittered geolocation information associated with a de-identified device id. We also provide partners with de-identified mobile device activity in aggregate, except in cases when the actual device id is needed, such as for targeted advertising, and for matching and measurement of advertising. De-identified and aggregated information is not Personal Data, and we use such information in a number of ways for our business intelligence services as we discuss in our Privacy Policy. We may also share aggregate, anonymized information with advertisers, clients, customers, and partners when providing our Services to those parties.

We may also share Personal Data with third party service providers, who process Personal Data on our behalf, and who agree to use the Personal Data only to assist us in providing our Services or as required by law. Our service providers may provide:

  • payment processing services;
  • cloud storage services;
  • web site hosting services;
  • maintenance and IT services;
  • customer support services;
  • analytics and metrics services;
  • email software; and
  • CRM software.

Some of these third parties may be located outside of the United States. However, before transferring your Personal Data to these third parties, we will either ask for your explicit consent or require the third party to maintain at least the same level of privacy and security for your Personal Data that we do.

We do not share or use your Twitter handle other than to authenticate your use on our Twitter-based Apps.

Cookies

A “cookie” is a small file stored on your device that contains information about your device. We may use cookies to provide basic relevant ads, website functionality, authentication (session management), usage analytics (web analytics), and to remember your settings, and generally improve our applications, websites, and Services.

If you would prefer not to accept cookies, you can change the setup of your browser to reject all or some cookies. Note, if you reject certain cookies, you may not be able to use all of our Services’ features. For more information, please visit https://www.aboutcookies.org/.

You may also set your browser to send a Do Not Track (DNT) signal. For more information, please visit https://allaboutdnt.com/. Please note that our Services do not have the capability to respond to “Do Not Track” signals received from web browsers.

Access & Review

If we process your Personal Data, you may have the right to request access to (or to update, correct, or delete) such Personal Data.

You may also have the right to opt out of having your Personal Data shared with third parties and to revoke your consent to our sharing your Personal Data with third parties. You may also have the right to opt out if your Personal Data is used for any purpose that is materially different from the purpose(s) for which it was originally collected or which you originally authorized. To submit these requests or raise any other questions, please visit our Consumer Choices and Opt Out Options page.

Exercising Access, Data Portability, And Deletion Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Data. To provide this information we need your mobile advertising device id (which is a unique id number assigned to each device). We ask you to complete a form and then follow the instructions to provide us with a legible image of your mobile advertising device id. To exercise the rights described above, please visit our Consumer Choices pages. We cannot respond to your request or provide you with Personal Data if we cannot verify your mobile device identity to confirm the Personal Data relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We provide you with reasonable access and deletion rights to the Personal Data. If you live in the EU, and wish to exercise your rights with respect to any Personal Data we hold about you, please visit our “Consumer Choices” pages.

We endeavor to respond to a verifiable consumer request promptly. If we require more time (than required by law), we will inform you of the reason and extension period in writing. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or unfounded.

Changes To This Notice

We reserve the right to amend this notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated information on our website.

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 Data, your choices and rights regarding such use, or wish to exercise your rights under GDPR, please do not hesitate to contact us.

Consumer Choices and Opt Out Options

Effective: 13 October 2021

Thank you for your interest regarding what personal information for data subjects in the: (i) European Union, UK or Switzerland pursuant to the European Directives 95/46/EC and 2002/58/EC (EU General Data Protection Regulations Legislation, also known as “GDPR”); (ii) California; and (iii) rest of the world is processed at Near. Pte. Ltd. Here is information about how you can control, delete or opt out of further sales with respect to this information.

Communication from Us

You can tell us to stop sending you marketing emails by clicking the unsubscribe link included at the bottom of the marketing emails. If you have provided us with contact information for a business relationship (sales) or customer support, you can ask us to delete this information using the email privacy@near.com. In some cases, We need to send you “transactional” emails relating to normal business operations. For example, we may email you to inform you about certain account activity. You cannot opt out of these emails.

Your Use of our Apps

When you utilize our mobile apps (“Apps”), we collect your twitter handle and information about how you use those Apps and/or respond to advertisements on those Apps. Tell us if you would like us to stop collecting information about how you use our Apps. Please note that you will have to repeat this process for each App and account.

Learn More >

Services

The categories of personal information collected by Near’s business services are mobile advertising device ids (MAID), IP addresses, advertising click stream information and location data associated with that device as discussed more fully in our Business Services Privacy Policy. Among other things, we do not collect an actual cell phone numbers or your name, full address or email address.

A sample of what personal information for a device is as follows:

  • Mobile advertising device id
  • IP Addresses and general (city or postal code) location data that can be extrapolated from an IP address
  • Latitude and longitude points
  • Timestamps with local dates and times and time zones

DO NOT SELL MY PERSONAL INFORMATION

CCPA ensures that Users are provided with the right to opt-out from their personal data being sold. If you would like to opt out of all sales of any personal information we may have associated with your device, please click here to complete a form to OPT OUT OF SALES. The information you supply to us for this request will only be used for the purpose of identifying the personal information about the device which you are requesting and responding to your request (including a record of our efforts).

DELETION REQUEST

If you would like us to DELETE the personal information we have associated with your device, please click here to complete a form to request DATA DELETION. The information you supply to us for this request will only be used for the purpose of identifying the Personal Information about the device which you are requesting and responding to your request (including a record of our efforts).

ACCESS

Certain jurisdictions also provide consumers with rights to request access (correction or portability) of the personal information held about them. We are not able to provide you with the particular file about any particular device because we are not able to confirm who the actual device owner is. We need your manufacturers’ advertising device id (the IDFAs for iOS, and Android Ad IDs for Android, “MAIDs”) in order to identify the device in our systems but we don’t have a way to confirm that the device MAID belongs to any particular person. We do not retain information that would match the device id to the actual owner, so we do not have a way to confirm that the consumer requesting the information is the same consumer that owns the device. It would require us to actually collect more personal information to try to verify who the device owner is, such as requesting their full name, address, and receipt of purchase of the device. Additionally we want to avoid the potential risk of providing a requestor who provides a MAID with the personal information that could belong to another individual. For example, the requestor takes a snapshot of the device id of his fiancée to request her personal information without her consent. If you are uncomfortable with our having any personal information about you, please complete the form to request a DATA DELETION.

Our Apps

For our Apps Echofon, UberSocial, and Plume, you log into the account using your Twitter credentials. We retain your Twitter handle as your account name but do not have access to your password. Twitter does. You can ask us at any time to delete your account on our Apps. Form here.

Please note that all of your Twitter post, timeline, profile and other information reside with Twitter and are not held by us. Please contact Twitter to exercise consumer choices with the information they hold. Please also note even if we delete your account upon your request, but you continue to use Twitter with your account information, that information is stored by Twitter and would be accessible again, if you decide to re-engage with our apps.