Privacy policy

Purpose of this privacy policy

This Privacy Policy explains the methods by which PATHZZ Pty Ltd (“PATHZZ”, “we”, “us”) collects stores and uses information on users (“Users” or “you”) to provide our consumer intelligence solutions.

Services

We provide consumer analytics and intelligence solutions to our clients and partners, defined as our Services. We provide consumer analytics tools to businesses and organisations. We use our proprietary technology and information collected from users to develop research and insight reports we then provide to businesses to help inform their business activities. This is primarily done using mobile location data with other supporting data points.

Information Collection

When you visit an App that has our data partners’ software development kit (“SDK”) installed, PATHZZ is able to collect particular Information about you and your device. Below, is the list of Information that PATHZZ collects and the purpose for doing so.

Information Collected	Purpose for Collection
Mobile ad identifiers, primarily Apple iOS IDFAs or Google Android IDs, for mobile apps	Data analytics and intelligence solutions
1st party cookies for websites
Timestamp
Location data
Phone carrier and connection type (e.g., cellular, wifi)
Browser type
Device type and language
Gender
Age
IP address
Hashed email address
Available or connected wifi SSID and/or BSSID names
App used

Information use and sharing

The Information collected by PATHZZ is aggregated from mobile app and website partners, specifically our data partners. It is then anonymised for the purposes of consumer safety and protection. We then make this Information available to our customers securely via our proprietary platforms as aggregated, anonymised and extrapolated models of consumer behaviour. This Information is then retained only to generate these consumer models and provide our Services. The organisations, businesses and companies that purchase products from PATHZZ then use this information to understand consumer trends across a variety of applications (“Services”). These include but are not limited consumer research (aggregate movement of consumers throughout a location), retail/place-of-interest analysis and evaluation (consumer retail shopping trends). Information will also be used for PATHZZ’s ability to provide and maintain the Services we offer, internal operational purposes, for example, to make product and service improvement, quality & assurance checks, and for our own sales and marketing initiatives. We may also use and share Information for legal and accounting purposes, for example, (i) compliance and cooperation in good faith with governmental organisations including law enforcement, (ii) maintain and protect the rights of PATHZZ and other, (iii) enhance and evaluate security and quality of Information and investigate potential misuse.

Opt-Out of Information Collection Related to our Services

• You can opt-out of sharing your location services directly via the operating system of your smartphone.
• Opt-out and delete your information processed by PATHZZ by following the instructions on our Device Opt-Out. Please note that we will need your Mobile Ad ID in order to identify your device in our systems. For further information, please contact us via the contact form on our website.

Opt-Out of Marketing Emails

If you would like to opt-out of receiving marketing communications from us, please contact us at privacy@pathzz.com to have your contact information removed from our marketing databases.

Information Collected when you visit our website

PATHZZ may collect information from you when you visit our website, for the purposes of expressing interest in our services and contacting us. Any information you send to us such as your name, email address and phone number may be used to market our products and services to you, for example contacting you about your query, or sending you information about new products and services. When you visit our website PATHZZ or third-party platforms with which we work may automatically collect information from your browser, desktop, computer, laptop and or mobile device, classified as “Site Data”. This information may include a pseudonymised browsing identifier, IP address, network information, device/browser information, activity on our website and data about the other webpages you visit, the associated date and time including web log data. This Site Data is used for analytics, marketing, research and website and services improvement. This Site Data may be correlated with a logged in user’s name and email address. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. Our Use of Cookies. We (or other companies we work with) may collect or associate Site Data using “cookies.” Cookies are small data files that have unique identifiers and reside, among other places, on your Devices, in emails we send to you, and on the web pages of the PATHZZ website. Among other things, cookies help us improve and personalise your use of the PATHZZ website. We may permit certain third parties to place cookies through the PATHZZ website to provide us with better insights into the use of the PATHZZ website and user demographics and to provide relevant advertising to you. These third parties may collect information about your online activities over time and across different websites when you use the PATHZZ website. For example, we utilise Google Analytics to analyse usage patterns for the PATHZZ website. Google Analytics generates a cookie to capture information about your use of the PATHZZ website that Google uses to compile reports on website activity for us and to provide other related services. Google may use a portion of your IP address to identify its cookie and for its commercial purposes. Our Use of Web Beacons. Web beacons are electronic images that may be used on the PATHZZ website or in emails we send to you. We use web beacons to deliver cookies, count visits, understand usage and effectiveness of offers, and tell whether you open an email and act upon it. By accessing or using the PATHZZ website, you consent to the placement of cookies on your browsers and devices and the use of web beacons as described in this Privacy Policy. You may block, delete, or disable cookies or web beacons to the extent permitted by your browsers, applications, and Devices as described in more detail below. However, if you do so, the performance of certain features of the PATHZZ website may be limited or not to work at all.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Information Security

All User Information is kept on servers that PATHZZ manages, using reasonable administrative, technical and physical safeguards designed to protect against unauthorised access or disclosure of data. 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, while we strive to use commercially acceptable means to protect information, we cannot guarantee or warrant its security. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

General Data Protection Regulation (GDPR) Addendum

This section relates to data collected from Users located in the Europe Union and United Kingdom. PATHZZ is the controller and responsible for your personal data. PATHZZ agrees and complies with all terms of the European Union General Data Protection Regulation (GDPR) and United Kingdom Data Protection Laws. Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please contact us on privacy@pathzz.com to request:

1. Access to your personal data
2. Correction of your personal data
3. Erasure of your personal data
4. Objection to processing your personal data
5. Restriction of processing your personal data
6. Transfer of your personal data
7. Withdrawal of your personal data.

We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Basis of Personal Data Processing

Under the Data Protection Laws, we have the right to process your Personal Data on the basis of:

• We have received your consent to do so;
• Processing is required in order to adequately perform a contract;
• We have a legitimate interests, or it is a legitimate interest of a third party (for example, a service provider or subcontractor)
• Processing is required to comply with an applicable law; or
• Processing is acceptable or required due to an applicable law or regulation.

Should we rely on your consent in order to collection Personal Data, you have a right to withdraw such consent at any time. Please email privacy@pathzz.com for further information and to opt-out. Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. subscribe to our service or publications;
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
• Third parties or publicly available sources. We will receive personal data about you from various third parties.
• Technical Data from the following parties:
  • Third party app publishers; and
  • advertising networks.
• Data we purchase from data brokers or aggregators.
• When our service provider provides it to us, or when you provide it to us as part of the contract fulfilment process.

Pathzz sends informational emails, articles, white papers, proposals, engagement letters, and information regarding our Services. We also use your Personal Information to conduct surveys. We do so either with your consent or because we have a legitimate beneficial business interest. Occasionally, we may desire to use your Personal Information in press releases and direct marketing materials. Before we use your Personal Information in that way, we will obtain consent from you. If you would like to opt-out of receiving marketing communications from us, please contact us at privacy@pathzz.com to have your contact information removed from our marketing databases.

Information Collection

Below, you can see the Information that PATHZZ collects and the purpose for doing so.

Information Collected	Purpose for Collection
Mobile ad identifiers, primarily Apple iOS IDFAs or Google Android IDs, for mobile apps	Data analytics and intelligence solutions
1st party cookies for websites
Timestamp
Location data
Phone carrier and connection type (e.g., cellular, wifi)
Browser type
Device type and language
Gender
Age
IP address
Hashed email address
Available or connected wifi SSID and/or BSSID names
App used
IP address, your interaction and usage of our website, operating system and referral URL	PATHZZ website
Email address, name, company name, phone number, organisation type	PATHZZ mailing subscription

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Lawful basis for processing including basis of legitimate interest
To provide services to our customers and creating and updating data sets	Consent
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	Necessary for our legitimate interests (to develop our products/services and grow our business)
Marketing informational emails, articles, white papers, proposals, engagement letters, and information regarding our Services	Consent

International Transfers

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above. Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. Processing activities may include accessing, storing, handling or otherwise using Personal Data with the use of third party service providers. Should PATHZZ use such service providers, PATHZZ acknowledges that it remains responsible for the work and activities of its subprocessors to the same extent it would be liable if performing the Services. PATHZZ subprocessors are not authorised to use any client Personal Data for any purpose other than those set out in the table above, and in accordance with our written instructions. Some of our service providers are located outside of the UK and the EEA, however, we will always ensure that any service provider located out of these areas maintain the same level of data security and protection as set out in this privacy policy.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

YOUR LEGAL RIGHTS

You have the right to: Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

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Last updated: 4 July 2023