Effective: 25 August 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.

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 as anonymized ids. Much of the information 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.co. We will respond to your request within a reasonable timeframe.

(A) Your rights in EEA, UK or Switzerland. You have the following data protection rights:

  • If you wish to access, correct, update or request deletion of your personal data, you can do so at any time by contacting us using the contact details provided under the Contact information section below. Additionally, we provide a form for all consumers to exercise the right to access their data, direct Near to delete their data, and opt-out of any further use of their data. The form is accessible here.
  • In addition, you can object to the processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data. You can exercise these rights by contacting us using the contact details provided under the Contact information section below.
  • Similarly, if we have collected and processed your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
  • The rights set out above may be limited in certain circumstances, e.g. If fulfilling your request would reveal personal data about another person, leading to infringing the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in local implementing legislation. We will inform you of relevant exemptions we rely upon when responding to any request you make.
  • You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority.

Upon receiving any of the above requests from you, we will need to verify your identity by asking you for your corresponding cookie identifier and/or, depending on the means/ platforms you have used to submit your request, we may need to ask you for an additional email confirming that the request is coming from you.

In case you have any questions about our data protection measures, the processing of your information or the protection of your rights as a data subject, you can contact Near’s data protection officer, details provided in the Contact information section below.

If you wish to communicate directly with our data protection officer (in case you have a particularly sensitive matter), please contact them by post, as communication by e-mail could always have security gaps. Please state in your request that your concern relates to Near.

(B) In California. The Site visitors who are California residents have certain rights under the California Consumer Privacy Act (“CCPA”) with respect to the personal data that we collect about you:

  • The right to opt out of our sale(s) of your personal data. We do not and will not sell your personal data in any manner that requires an opt-out opportunity under the CCPA.
  • The right not to receive discriminatory treatment for the exercise of your opt-out right conferred by the CCPA.

We provide a form for all US consumers to exercise the right to access their data, direct Near to delete their data, and opt-out of any further use of their data. The form is accessible here.

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.