Last Updated: May 28, 2021
This Policy also describes applicable data protection rights including a right to object to some of our processing.
To read our entire policy, see below.
- What Data Does N’Gale Collect
Data You Provide To Us:
We collect data that you provide to us when you create an account, such as, email address, nickname, phone number, the city, state and country in which you created your account, and, where applicable, your social media username and other data if you create an account using third party log-in credentials (please see “Data Received From Third Parties” below).
We may also collect other data you provide when you use the Consumer Services, including pictures you upload, messages you send through the App, searches, likes, follows, check-ins, tips, survey responses, demographic information, and any other data that you voluntarily provide to us.
Data Collected Automatically When You Use Our Consumer Services:
If you opt in to sharing your location with us, we automatically receive data about your precise location (e.g., latitude-longitude coordinates) whenever you use the Consumer Services (e.g. open our mobile App, visit our website, etc.). If you opt in to have background location on in our App, we will collect data about your location when you are not using the App and when the App is closed (as permitted by your device settings).
We also collect additional data about you when you use the Consumer Services. For example:
- data about how you interact with the Consumer Services, such as your search words, page views, date and time of interactions, time spent on each page, or posts you make;
- device information, such as your hardware model, operating system and version, unique ID and device data such as device identifiers, IP address, sensor data, browser type, language, and wireless network, mobile device name, types of mobile apps installed; and
- data from cookies, pixels and other technologies, such as cookie ID, advertising ID or other unique advertising ID, web beacons, and local storage. You can control certain types of cookies through your browser settings or other tools.
Data Received From Third Parties
We may receive data about you from third parties, including:
- our Enterprise Customers (e.g. business customers of our Products);
- third parties that provide services to us, such as unaffiliated apps and websites, offered by our business partners, including those from whom we license data; and
The information we obtain from third parties includes demographic data, data about how you interact with the third party’s websites, apps and smart TVs and streaming devices, device data (including mobile device and advertising identifiers, such as Apple IDFA or Google Advertising ID), and information from cookies, pixels and other similar technologies. In the event that we obtain data about you from our Enterprise Customers and third parties, we will combine all data collected about you into one single profile.
- How Is My Data Used by N’Gale?
To Operate, Maintain and Improve The Consumer Services
We use your data to operate, maintain the Consumer Services, and our business, and to understand you better and personalize the Consumer Services. To do so, when you download more than one App, we combine your data that we obtain in each App. In addition, if you use the Consumer Services when you are not logged into your N’Gale account, when you subsequently log in to your N’Gale account, we combine data collected while you were not logged in.
We use various technologies to determine your precise location, such as the location services of your operating system or browser, sensor data from your device (e.g. magnetometer, barometer, gyroscopes, accelerometers, compasses, Bluetooth data, beacon data, Wi-Fi access points, GPS data, and cell tower data), and other data that may help us understand your precise location.
If you have opted-in to sharing your background location with us in our App, you may remove your permission at any time by going into your operating device settings and toggling off background sharing.
We also use your data to improve the Consumer Services and our business, conduct research and development, perform analytics, develop and offer new products and service, and to infer certain details about you, including details about you, your interests and whether separate devices (e.g. mobile phones, tablets, and/or TVs) are owned by you or by members of your household. For example, we may customize the Consumer Services to allow you to add friends from your device’s contact list who are also using the Consumer Services or, if applicable, your Facebook, Google or Twitter account, if you have opted to connect these accounts to your N’Gale accounts). We do not store your contact lists. As another example, we also use your data to help us map Locations (as defined below). For example, we may use device signals to determine that a particular device is within a particular venue. Additionally, if you consent to sharing crash data (when the App crash) with us, we may use that data to help us analyze the cause of the crash and improve the Consumer Services.
Communicate With You
We use your data to communicate with you by email, text (if you opt-in), or in our App, about new product offerings, updates to the Consumer Services, or anything else we think may be of interest to you. To opt out of receiving marketing communications, please send an email with the subject Opt-Out to firstname.lastname@example.org
Protection of Our Rights
We use your data in our business products and services (“Products”) that we offer to our partners. In particular, we receive data from unaffiliated apps, websites, smart TV providers, online advertising services, and our partners, which we may use to send you advertisements that are tailored to your interests or to measure whether an ad that you were exposed to resulted in a visit to a physical store. The data collected for this purpose includes data about how you interact with the Consumer Services or with unaffiliated websites, and apps, device data, and data from cookies, pixels or other similar technologies.
We combine the data described above with demographic data, location and other interest-based segment data obtained from third parties, including data obtained from the Enterprise Services to provide our Products.
- When Is My Data Shared?
Data That May Be Shared With Other Users
When you use the N’Gale App and Sites, your authorized friends may see some of your data (e.g. name, profile photo, hometown, users you are following, your followers, and other information you post). When you communicate using the N’Gale App and Sites, such as when you direct message your friends or check-in to a store, restaurant or a location (each a “Location”), your friends may see this data. You can always control what you want visible to others, including your friends, in your “Settings”.
Publicly available data includes your public profile, tips, likes, saves, photos, lists you create and follow and lists of followers. Public data may be searchable by search engines and be shared with third parties, including through our Products.
Data That May Be Shared With Affiliates, Service Providers and Partners
We may share your data with our affiliated entities, and service providers that perform services on our behalf, such as cloud storage, IT services, marketing, analytics and search engine and other software services. These service providers may be located in countries other than the country in which the information originally was collected, such as the United States and Canada. We do not authorize our service providers to retain, use or disclose the data except as necessary to perform services on our behalf or comply with legal requirements.
In addition, when we partner with a business, we may share your mobile advertising identifier or another identifier, and other data such as inferred visits to public locations (such as a store or a restaurant) or as a part of a chain of inferred visits (such as this device went to Mike’s Convenience Store, then Emily’s Pilates Studio, and then after, Jerry’s Salad Bar). We do not share your latitude and longitude coordinates, and we do not share inferred home and work location. Data is only shared after it has been processed into an inferred visit to a public location. We may also assist our business partners in combining the data we obtain when you use the Consumer Services with the data, we receive from those business partners about online or offline advertisements that you may have viewed (including on unaffiliated apps, websites, and billboards). We do this so that our partners can serve targeted ads, measure the effectiveness of their ad campaign, perform analytics and/or understand you better based on preferences that we infer about you. We may also share data to our developer community or third parties for analytical or other purposes.
Data That May Be Shared With Our Affiliates and Subsidiaries
We may share data with our affiliates and subsidiaries in order to improve the Consumer Services, develop and offer our Products, and for other purposes.
Compliance with Law, Protection of Rights and Corporate Events
We may share data (i) if we are required to do so by law or legal process (such as a court order or subpoena); (ii) in response to requests by government agencies, such as law enforcement authorities; (iii) to establish, exercise or defend our legal rights; (iv) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (v) in connection with an investigation of suspected or actual illegal activity; or (vi) to protect the rights, property, or safety of N’Gale and our products and services, our employees, or users and others.
We may also share data as part or in anticipation of a business sale, merger, consolidation, investment, change in control, transfer of substantial corporate assets, reorganization, liquidation, or similar business transaction or corporate event.
When You Consent
We will also share your data with your consent.
- What About Cookies and Similar Technologies?
We may use technologies like cookies, pixels, web beacons, local storage and other automated technologies on our Sites, in our emails, within our App, and sometimes in third party apps that use our APIs or SDKs to provide you with a range of products and services. We use these technologies for a number of purposes, such as for authentication, security, preference settings, in our Products for advertising, measurement and analytics.
- How do I Access or Delete My Data?
You may access and update your data at any time through the “Edit Profile” section in your N’Gale App. You may also request a copy of your data by sending an email to email@example.com
You may also request to delete your data and account at any time by sending an email to firstname.lastname@example.org
If you delete your data, your profile, including your check-in history, tips and photos, will be removed from the Consumer Services, and you will no longer be able to access such data. We will not be able to restore your account once it has been deleted. Deletion of your account may not be immediate. Residual copies of your personal information or posts may remain on backup media for a short period of time thereafter.
We may also retain data as required by applicable law and we may retain data that has been anonymized or otherwise does not constitute or contain personal information.
If you have questions about accessing, updating, or deleting your data, please email email@example.com
If you are from the EEA, UK or Switzerland, you may also have additional rights, which are summarized under “More Information for Consumers from the EEA, UK or Switzerland” below.
- Personal Information Retention
- How We Protect Personal Information
We maintain administrative, technical and physical safeguards designed to protect personal information we obtain through the Consumer Services against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
- Children under 13
Our Consumer Services are intended for a general audience and are not directed at children. We do not knowingly collect personal information online from individuals under the age of 13 or such other age as may be directed by applicable law.
- More Information for Consumers From the EEA, UK and Switzerland
Where GDPR applies to the processing of your Personal Data, we rely on several legal bases. These include:
- When the processing is necessary to perform our contract with you, such as our Terms of Service. This may include providing you with our Consumer Services or tailoring the Consumer Services to your preferences;
- When the processing is necessary for our legitimate business interests (or those of our Enterprise Customers), including but not limited to, improving the Consumer Services or providing our Products;
Subject to applicable law, you may have a number of rights regarding the processing of your Personal Data, including:
- the right to request access to, or copies of, your personal data that we process or control, together with information regarding the nature, processing and disclosure of that personal data;
- the right to request rectification of any inaccuracies in your Personal Data that we process or control;
- the right to request:
- deletion of your personal data that we process or control; or
- restriction of processing of your personal data that we process or control;
- the right to object, to the processing of your personal data by us or on our behalf;
- the right to have your personal data that we process or control transferred to another data controller, to the extent applicable;
- the right to withdraw where we process your personal data on the basis of your consent, and
- the right to file a complaint with a Data Protection Authority regarding the processing of your personal data by us or on our behalf.
These rights may be limited in certain circumstances, for example if fulfilling your request would (i) reveal personal data about another person, (ii) infringe the rights of a third party (including our rights), (iii) cause us to delete information that 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.
Transfers of Data to the United States
Who is Responsible for Your Data?
- Contact Us
Kirkland, WA 98033-7465 USA
We will make every effort to resolve your concerns.