Privacy Policy

Website Privacy Policy

Effective: 19 April 2023

This Website Privacy Policy (“Website 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 Services Privacy Policy.

1. Policy coverage

This Website 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.com. Our website is primarily designed to provide information to our customers and partners, which are typically businesses.

This Website Policy lays down applicable data protection rights of the website visitors and their right to object to processing their information.

In order to use our website, 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 Website

(A) Near Website

When you visit our website 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.

(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 website 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 website, 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 website 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 website, 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 website 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 website 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 Website Policy.

If you decide to use any of the links available on the website, 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, website 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 18 through the website. If you are below the age of 18 years, you should not use this website or provide any information about you to us. If we are made aware that we have received personal information from someone under 18 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 “Services Privacy Policy”

(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 Website Policy

This Website 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 Intelligence, Inc.:

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

Near Intelligence, Inc.. 100 W Walnut St, 4th Floor Pasadena, CA 91124

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.

Privacy Notice - California CCPA

Effective on: 11 April 2023

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Services Privacy Policy of Near Intelligence, Inc. (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.

Under the California Consumer Privacy Act of 2018, “Personal Information” is defined as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information includes, but is not limited to, the following if it identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household and includes all of the following categories of 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

When you use an app or visit a website that uses advertising software placed by us or our Partners, we and our Partners may collect your mobile advertising identifier (MAID) from your device, internet protocol (IP) address, location data (including latitude data / longitude data), browser type, device type, time stamp, operating system and version, language preference, hashed email address (HEM), the names of other mobile apps you use and how you browse the app or website. We also collect demographic data (age and gender) and social media data.

We obtain the categories of Personal Information listed above from our Partners' apps and websites, including:

• Partner software, including Software Development Kits and cookies, used in publisher apps and websites (the owners and sellers of digital advertising space).
• Application programme interface (API) connectors – our APIs are connected to our Partner's APIs to share data.
• Mobile advertising network providers who share data with us and our Partners for targeted advertising purposes).

We also collect data from other trusted third party providers and publicly available sources such as social media sites, census data providers and certain public directories.

Use of Personal Information

We may use your personal data for all or some of the following purposes:

• Targeted advertising services. We help our advertising and publishing customers provide more relevant advertising and content that is aligned with users' interests. For example, we group users into audiences: sports fans, car enthusiasts, movie goers, travellers, and measure the effectiveness of campaigns.
• Staggered advertising. We assign a randomised "Near ID" to replace your MAID which enables us and our Partners to know if your browser or device has previously been served the same advertisement.
• Cross-device advertising. In some cases, we can infer that two different devices are used by the same user, we can then use that information to deliver targeted advertising across multiple devices.
• Data intelligence services. We transform MAIDs, approximate geolocation information and the other data we collect (detailed above) into actionable insights for our customers. We provide customers with trend and statistical analyses, such as for identifying and optimizing trade areas and business locations, and for helping our customers make informed business decisions about consumer behaviour with trend and movement information. We provide actionable insights, patterns and commonalities to enable our customers to evaluate products and services they offer, such as enabling engagement with audiences and improving user experience of their apps and websites.
• Improving our services. We use your personal data to improve the way we work, improve our services, and provide additional services such as insights.

As discussed more fully in our Services Privacy Policy, 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 Services Privacy Policy, including for marketing and targeted advertising and data analytics.

Third parties that support us in targeted advertising include:

• Adsquare GmbH (privacy policy is here)

Your Rights And Choices

California residents are entitled to the following privacy rights listed below:

• The right to know. You have the right to request to know (i) the specific pieces of Personal Information we have about you; (ii) the categories of Personal Information we have collected about you; (iii) the categories of sources from which that Personal Information was collected; (iv) the categories of Personal Information about you that we have sold or disclosed; (v) the categories of third parties to whom your Personal Information was sold or disclosed; and (vi) the purposes for collecting and selling your Personal Information. Generally, we have collected and sold or disclosed the categories of Personal Information detailed in the section titled “Personal Information We Collect” above. We do not “sell” or “share” the personal information of known minors under 16 years of age.
• The right to access. You have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use, disclose, sell, and share.
• The right to deletion. You have the right to request that we delete the Personal Information that we have collected or maintain about you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your personal information was collected. If we deny your request for deletion, we will let you know the reason why.
• The right to correctio. You have the right to request that we correct inaccurate personal information that we maintain about you, subject to applicable legal exceptions.
• The right to opt out of the sale or sharing of your Personal Information. You have the right to opt out of the sale or sharing of your personal information. You may opt out of the sale or sharing of your personal information using the following link “Do Not Sell My Personal Information” or by contacting us using the information below.

California residents may exercise the rights described above by contacting us as follows: privacy@near.com.

We may require verification of your identity before further processing your request. In certain instances, we may be permitted by law to decline some or all of such 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 rights available under California law.

Shine the Light

California residents are entitled to request and obtain from us once per calendar year information about any of your Personal Information shared with third parties for their own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information. To request this information, please contact us at privacy@near.com..

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 along with the date such changes were made effective.

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:

Address: Near Intelligence, Inc. 100 W Walnut St, 4th Floor Pasadena, CA 91124

Email: privacy@near.com

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.

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.

Sensitive Data Policy

Effective: 25 Aug 2022

Our mission is to help companies, tourist bureaus, and other customers grow by utilizing our business insights. In addition to following federal and state privacy and data regulations, we abide by the following principles to avoid the misuse of our data:

• We do not accept and will terminate a client if we learn of any dishonest or illegal practices on their part.
• We do not allow use of our data by law enforcement.
• We do not allow use of our data to target advertising to people below the legal age (for example, alcohol and casinos) or to create audiences for locations primarily visited by children (such as preschools, playgrounds).
• We do not allow use of our data for employment, credit, health care, or insurance purposes.
• We do not allow use of our data to target vulnerable or sensitive communities (for example, by political, religious, sexual orientation or medical affiliation), or to identify those within sensitive areas (e.g.conflict zones, hospitals, protests, religious sites, clinics, etc) or to places.

Cookie Declaration Policy

This policy was last updated on 22 September 2022

Contact us

We are Near Intelligence Inc.

If you have any questions about this policy, including any requests to exercise your legal rights, please contact us at privacy@near.com or write to our Data Protection Officer, Prof. Dr. Christoph Bauer, CEO at:

• ePrivacy GmbH, Große Bleichen 21, 20354 Hamburg, Germany; or
• Near Intelligence Inc. 100 W Walnut St, 4th Floor Pasadena, CA 91124

Further Information

For more information on how we use cookies and how we use your data, please see our Website Privacy Policy, Partner Advertising Privacy Policy and Near Advertising Policy