PRIVACY POLICY
Global Wireless Solutions (“GWS”) values the privacy of its users. This Privacy Policy
(“Privacy Policy”) provides information about (a) the information that GWS collects
and services (collectively, the “Services”), (b) the ways in which such information is
used by GWS and shared with third parties, and (c) your choices regarding use and
disclosure of your information. By using our Application, you (“you” or “your”)
consent to the policies and practices described in this Privacy Policy.
As used in this Privacy Policy, the term “Personal Information” means information
that identifies you personally, alone or in combination with other information
available to us by reference to an identifier such as your name, device identification
number, precise location data, personal online identifier, or other factors specific to
you. Personal Information includes special categories of Personal Information (or
“Sensitive Personal Information”) but excludes anonymous information, information
that has had the identity of an individual removed or replaced with a pseudonym,
such that the information cannot be uniquely associated with you personally without
additional Personal Information supplied by GWS.
“Special categories” of Personal Information require a higher level of protection. This
includes information about a person’s racial or ethnic origin, political opinions,
religious and philosophical beliefs, trade union membership, genetic data, biometric
data, health data and sex life and sexual orientation. The information collected by
GWS arguably includes “special categories” of Personal Information, i.e., sexual
orientation and religious opinions are likely to be discernible from browsing history,
app usage or other behaviors. For the purposes of GDPR, GWS can only processes
such information on one of the lawful grounds set out in Article 9 of the GDPR such
as “explicit consent” from the individual, which is a higher threshold than “consent”
(Article 9(2)(a)).
Information collected by GWS
GWS is a technology company that enables market research companies, investment
research companies, marketing companies, digital advertising companies and other
third parties (collectively, “Partners”) to conduct research on user behaviors. When
you access and use our Services, GWS may collect information (i) that you knowingly
and voluntarily provide when you use our Services (such as through forms or profile
screens) including, without limitation, registration/account setup information, and
(ii) that we are able to collect as you use your mobile device and other applications.
GWS collects this information with your consent in order to allow Partners to pursue
their legitimate interests of:
* improving their service experience; and/or
* developing new products and service features
The Application will run in the background and sends information to us
automatically. The information that we collect and use may typically include, without
limitation, the following kinds of technical and usage data:
* Technical Data: IP address, device type, operating system, network type and speed,
local time zone, device type, battery life, advertising ID, phone identity, location (GPS
and network-based)
* Usage Data: internet usage, browser and URL history, application usage, and other
information about how you use your mobile device and applications
GWS will use Personal Information for various market research and business
purposes such as providing customer service, fraud prevention, market research, and
improving our Services.
We will also use or share aggregated, anonymized, or pseudonymized information
that we collect from you for the purpose of market research on brands and products,
marketing campaigns, advertising efficacy and investment research, as described in
this document.
How is Personal Information used by GWS?
We will only process your Personal Information, including sharing it with Partners,
for a purpose described in this Privacy Policy, where (1) you have provided your
consent which can be withdrawn at any time, (2) the processing is necessary for the
performance of a contract we are about to enter into or have entered into with you,
(3) we are required by law, (4) processing is required to protect your vital interests or
those of another person, or (5) processing is necessary for the purposes of our
legitimate commercial interests, except where such interests are overridden by your
rights and interests.
We primarily use this information for market research regarding user preferences
and habits and to facilitate other opportunities with respect to the Services.
Information we collect from you may be provided to Partners as part of our services,
only as strictly set forth below, and on the basis of your consent provided when you
install the Application and agree to this privacy policy and terms of service, among
other terms. You can opt-out at any time, either temporarily or permanently, as
described in this document.
We may use Personal Information we collect about you on its own or combine it with
other information we have about you to:
* Create user accounts and/or profiles through registration;
* Perform internal operations, such as tracking and improving the effectiveness of
our Services and market research efforts;
* Provide you with the opportunity to earn rewards for using the Services;
* Personalize user experiences, such as remembering your settings and preferences
for things like language, font size, etc.;
* Provide customer services and support;
* Resolve disputes between users and/or a user and GWS as set forth in our Terms of
Use;
* Prevent fraud or deliver other location-based services;
* Administer user rewards;
* Conduct surveys;
* Conduct research;
* Receive feedback;
* Conduct audits;
* Prepare reports and analyses for our Market Research Partners;
* Provide information to our business partners;
* Provide information to our representatives and/or advisors, such as our attorneys,
accountants, and others to help us comply with legal, accounting, or security
requirements;
* Transfer your information as part of a merger or sale of the business;
* Protect the rights, safety, and information of our members, third parties, as well as
our own; and
* Comply with legal requirements, such as in response to a subpoena or similar
investigative demand.
We may also disclose your Personal Information as otherwise set forth in this Privacy
Policy, as permitted by law, or with your consent.
Who can access the information we collect?
1. Access to Personal Information
GWS may disclose your Personal Information in the following instances:
* Agents. We employ other companies and individuals to perform functions on our
behalf. Examples of such functions include, without limitation, using Paypal for
compensating panelists, using Amazon Web Services for server and database
infrastructure, using Zendesk for panelist support, and other similar services. We
share our users’ Personal Information with these agents as we deem necessary for
such third parties to perform their functions.
* Employees. Only authorized employees have access to your Personal Information.
* Affiliates. When you are asked for information while on our Services, you are
sharing that information with GWS and our various affiliates and sister companies,
unless specifically stated otherwise. As a result of this sharing, you may receive
communications from any of our affiliates.
* Authorized Business Partners. These include, without limitation, agents,
contractors, vendors, licensors, system integrators, etc. GWS, our affiliates and our
business partners may share this Personal Information with each other and use it
consistent with this Privacy Policy. They may also combine it with other information
to provide and improve our market research services.
* To Comply with Legal Process, Protect GWS, or Enforce our Rights. We may release
your Personal Information when it is necessary to (i) conform to legal requirements
or comply with legal process; (ii) enforce or apply our conditions of use and other
agreements (iii) protect the rights, safety or property of GWS, our affiliates, service
providers, our users or the public, or (iv) prevent a crime or protect national security
(including, without limitation, exchanging information with other companies and
organizations for fraud protection and credit risk reduction).
* As Part of a Merger or Sale of Business. We may disclose your Personal Information
in connection with a substantial corporate transaction, such as the sale of our
business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event
of bankruptcy.
* Named Market Research Partners. We may share Personal Information with
Named Market Research Partners. For the purpose of this Application, the Named
Market Research Partners are Global Wireless Solutions, Inc (“GWS”) and Sense360
(“Sense360”). The information that we share with these Named Market Research
Partners is further set forth below.
* For any Other Market Research Partners, Investment Research Partners, Third
Party Marketing Partners, Digital Advertiser Partners (collectively, “Other Partners”),
we only share information that is either aggregated, anonymized or pseudonymized,
as described in this document. Other Partners license this information and utilize our
other capabilities to develop insights-based products and services, which Other
Partners can in turn deliver to their clients and customers.
The Application Does Not Contain Any Spyware or Adware
We do not serve pop-up or pop-under advertising through the software and the
software does not install hidden, ad-supported programs onto users’ mobile
phones.
For users in North America, the Application includes measurement technology. This
will periodically measure your location through GPS and Wireless Networks (Wi-Fi
and/or mobile networks), Bluetooth and beacons, if these functionalities are
available on your device. Location data is collected in conjunction with other the
data elements, such as information on network performance and signal quality, as
set forth below.
Once you have agreed to participate, GWS measurement technology will collect and
transmit other information, including the following:
* The type, name and use of applications. GWS uses this information to gauge how
well the application performs on your carrier’s network.
* The date, time, and duration of phone calls, but not the content of your voice
communications. GWS uses this information to measure mobile device and network
functionality, including whether calls go through or are dropped.
* The date, time, speed, networks (including Wi-Fi and SSID), and duration of data
sessions. GWS uses this information to evaluate how well your carrier’s network
performs.
* The battery, device stability and network performance of your device, including
signal quality readings and information about failed calls and data transfers. GWS
uses this information to evaluate how well your carrier’s network performs.
* Answers to survey questions that are presented to you as a result of your
participation as a panelist. GWS uses this information to better understand your
satisfaction with your carrier’s performance and other information.
Children and privacy
Our Services are not directed to people under the age of 18. If you are under 18
years of age, do not use our Services.
We do not knowingly collect Personal Information from people under the age of 18.
If we learn that Personal Information of persons less than 18 years-of-age has been
collected through our Services, we will take the appropriate steps to delete this
information.
Security, storage and retention
1. Security
GWS takes reasonable technical and organizational precautions to protect the
confidentiality, security and integrity of your Personal Information. Although we use
security measures to help protect your Personal Information against loss, misuse or
unauthorized disclosure, we cannot guarantee the security of information
transmitted to us over the Internet. There is no guarantee that information may not
be accessed, disclosed, altered or destroyed. You are responsible for maintaining the
secrecy of your account information, and for controlling access to your email
communications and personal accounts.
2. Storage
The Personal Information that you provide to GWS is generally stored on servers
located in the United States. If you are located in another jurisdiction, you should be
aware that once your Personal Information is submitted through our Services, it will
be transferred to our servers in the United States and that the United States
currently does not have uniform data protection laws in place.
3. Retention
We will store your Personal Information, in a form that permits us to identify you, for
no longer than is necessary for the purpose for which the Personal Information is
processed. We may retain and use your Personal Information as necessary to comply
with our legal obligations, resolve disputes, and enforce our agreements and rights,
or if it is not technically and reasonably feasible to remove it. Otherwise, we will seek
to delete your Personal Information within a reasonable timeframe upon request.