End User Privacy Policy

Last updated: February 2019

About this End User Privacy Policy

Oriient New Media Ltd. (“Oriient“, “we“, “our” or “us“) is committed to your privacy. This End User Privacy Policy (“End User Privacy Policy“) describes how we collect, use and share information through our SDK (Software Development Kit) and the services we provide through it (the “SDK” and “Services” respectively).

In this End User Privacy Policy the term “Developer” means a third party that develops or distributes an Application which integrates our SDK and/or Services. “Application” means an application developed and/or distributed by a Developer. If you are a developer, please refer to our “Developer Privacy Policy” available at www.oriient.me/developer-privacy-policy.

1.  Introduction

Developers may use our SDK and/or Services as a part of their Application. If you are reading this, it’s probably because the Application you downloaded or otherwise using integrates our SDK and/or Services.

By using the SDK or Services in the Application, you agree to this End User Privacy Policy. Please read this End User Privacy Policy carefully before using the Application.

If you do not agree to this End User Privacy Policy, do not press “I agree” (or any other form that appears in the Application you use) or please promptly stop using the Application.

2.  What information we collect

The information we collect through our SDK and Services include:

• Location information of your device in order to provide certain Services related to your location and that are dependent on data related to the geographic location of your mobile device on which the Application and SDK are installed.
• Sensor data from your mobile device (such as, if available, data from your accelerometer, magnetometer, gyro sensor, barometer, proximity sensor and brightness sensor of your device).
• Radio scanning results from the various device radios (such as, if available, WiFi BSSID/SSID, Bluetooth / BLE information, cellular radio base station CID/LCID).
• Other device data, including the device manufacturer, model and operating system information.
• A unique and application-specific identifier (“UUID”) created by us and generated for each app installation in order to facilitate session management. The UUID is generated for a specific Application that uses the SDK but it is not similar to the device’s IMEI code, WiFi, MAC address, Bluetooth address or other persistent hardware-originated identifier.
• The SDK also recognizes the Developers of the Application that use our SDK and Services with a Developer-specific API authentication key, an application name/version and the SDK version used.
• At times the SDK sends runtime metrics of itself to us, to monitor and optimize the SDK performance. Please note that we do not collect any personal information through our SDK and Services. This may not be the case in the Application you are using. Also note that although Oriient uses your information on an anonymized basis, nevertheless, the Application you are using may have the capability to de-anonymize such data and/or use such anonymized data in combination with other data that you may have provided, which may render such information personal. In light of this, we advise you to read carefully the privacy policy of any such Application and be mindful of the personal information you submit in connection with such Application.

3.   How we use information we collect

The information we collect will be used for the following purposes:

• Provide our services to Developers of the Application you use;
• Operate,  manage and provide features for the Services;
• Develop, improve, protect, audit and analyze the Services, including by way of providing aggregated analysis using anonymized information to our Developers (e.g. for creating heat maps);
• Ensure the technical functionality and security of the Services; and
• Prevent and investigate fraud and other misuses and protect our rights and/or our property.

4.  With whom we share information we collect

The information we collect may be shared with third parties in the following circumstances:

• We transfer or share the information we collect with the Developers.
• We transfer or share the information we collect with other trusted third party service providers, who are located in different jurisdictions across the world, for the purpose of: (a) storing or processing such information on our behalf or to assist us with our business operations and to provide and improve our Services; (b) performing research, technical diagnostics, analytics or statistical purposes.
• We may share information we collect if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with applicable law, regulation, legal process or governmental request; (ii) enforce our policies, including investigations of potential violations; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; or (v) prevent harm to the rights, property or our or our users’ safety, or any third party.

5.  Access to information, Information Correction, Retention and Deletion

You have the right to request access to information we have collected about you or if you believe that the information we have about you is incorrect or missing or if at any point you want us to delete information about you, you can do this by contacting the person or entity specified in the privacy policy of the Application you are using. Any collected data will be retained for a period that is the shorter of: (i) a period of three (3) years from the date of collection thereof; or (ii) for as long as it is needed for the purposes specified in sections 2 and 3 of this End User Privacy Policy; and shall thereafter be deleted. Please feel free to contact us at info@oriient.me; we will make sure to provide you with reasonable assistance as needed and to the extent under our control. In order to comply with your request, we may ask you to verify your identity.

6.  Third party practices

This End User Privacy Policy does not apply to the practices of companies that we do not own or control or to individuals whom we do not employ or manage, including any of the third parties to which we may disclose information as set forth in this End User Privacy Policy, such as the Developers or third party service providers.

Please be sure to review also the privacy policy of our Developers of the Application in question or third party service providers (as applicable).

7.  Children’s privacy

We do not knowingly collect information from children under the age of 13. If we learn that we have collected information from a child under the age of 13, we will delete that information as promptly as possible. If a parent or guardian becomes aware that his or her child (or minor under supervision) has provided us information without their consent or information that they would like to have removed, they should contact us at: info@oriient.me.

8.  Security

We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect the information we collect. However, 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 the information, we cannot guarantee its absolute security or confidentiality. If you have any questions about security on the information, you can contact us at info@oriient.me.

9.  International Transfer

The information we collect may be transferred to, and processed or maintained on computers and servers located outside of the state, province, country or other governmental jurisdiction where you reside and/or where the information data was collected. The privacy laws in such areas may not be as protective as those in your jurisdiction. Your consent to this End User Privacy Policy represents your agreement to that transfer. In particular, if you are located within the European Union, please note that information collected by us may be transferred outside the European Union / European Economic Area and you consent to such transfer.

10.  Merger, Sale or Bankruptcy

In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign information, including personal information in connection with the foregoing events. In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this End User Privacy Policy.

11.  Changes

We reserve the right, at our discretion, to revise or update this End User Privacy Policy at any time. Any material change will be effective seven (7) days following posting the revised End User Privacy Policy. The last revision will be reflected in the “Last Updated” heading. You are advised to consult this End User Privacy Policy regularly for changes.

12.  Contact us!

If you have any additional questions or queries about our End User Privacy Policy, please contact us by email at info@oriient.me.