California Users: If you are located in California, then under the CCPA (California Consumer Privacy Act), you have a right to opt-out of the sale of your information. To do this, you can contact the concerned sales person that you communicate with or you can mail us at email@example.com.
NybSys, a global company with its headquarters at FNB Building, Betfusile Street Mbabane, PO Box 213, Eveni H103, Eswatini, provides a number of IT and Telecommunication solutions and we collect relevant information from you to serve you with the best services.
Table of Contents
- Background: What Does Nybsys Do?
- What Information Do We Collect?
- How Do We Use the Information We Collect from Our Services?
- How Do We Use the Information We Collect from Our Visitors?
- Who Else Do We Share Information We Collect With?
- Consumer Choices & Opt-Out Options
- International Transfers
- Children’s Data
- Addendum for California Residents Privacy Rights
- Contact Us
1. Background: What Does NybSys Do?
NybSys is a dynamic and fast-growing technology solution provider with a global presence. The company specializes in combining modern technology with proven business expertise to provide business analysis, software design and development, hardware, networking, and communications solutions. NybSys provides other services (such as advertising, data analytics, and data research) using the information and location-centric data that we compile about the movement, activities, and places mobile devices visit.
The information we provide helps marketers and advertisers learn about their potential audiences and Trusted Partners, and helps research organizations form insights for financial, market research, traffic and city planning, smart cities, or educational purposes. We also work with government agencies or health organizations interested for purposes of research, security, anti-crime and law enforcement, or civic, etc.
2. What Information Do We Collect?
We use our NybSys Development Kit to collect information, including mobile advertising IDs (e.g., iOS IDFAs and Android Advertising IDs), location information (as described below), and other information related to how different types of Devices and their users interact with mobile advertising services. We also receive this same information from Server to Server partners. We provide our Kit to Publishers to help them monetize their Apps using location in order for them to provide free media, games, and other mobile services and activities such as weather forecasts or traffic updates.
Advertisers use the location data collected by the NybSys Development Kit in Apps, and received from Server to Server partners, to enhance their ability to show ads in both web and mobile apps, to target more relevant ads in general, and to analyze how well ads perform in the two platforms. Some advertisers may use location data or “interest segments” across devices or browsers (e.g., tablets, mobile devices, browsers, or televisions)
When you download and use an App that uses our Services (the NybSys Development Kit) and have System Location Services “On” and Limit Ad Tracking “OFF”, the system can collect certain information through or about the Device, in particular:
a. Precise Location Data:
- Geolocation of the Device, usually expressed by latitude-longitude coordinates obtained through GPS features of our kit, WiFi data, cell tower triangulation and other techniques.
- Dwell time near points of interest (or how long your device stayed at one place).
b. Relative Location Data:
- Bluetooth Low-Energy (BLE) sensors, or beacons,
- Signals from the Internet of Things (IoT) devices.
- Near-field Communication (NFC)
- The GPS capabilities of our system allow it to receive signals from each of these technologies that show when a Device is close by. For example, many retail stores have beacons that detect when a Bluetooth-enabled Device passes by or goes into the store. Shopping malls, stadiums, restaurants, museums and other similar points of interest may also use beacons.
c. Advertising IDs, or Unique Device Identifiers for Advertising (Android ID or iOS IDFA)
d. Time and Date Information
e. Event information about your Device, which means:
- Any crashes
- System activity
- Hardware settings
f. Usage Data is automatically collected and cannot identify an individual user, which means:
- Device type (i.e. iPhone 7)
- Operating system version and type (i.e. iOS 13.2)
- Device settings (for example whether or not you have enabled Location Services)
- Device time zone
- Device carrier
- Current IP address
- Applications on which our kit is embedded
a. Voluntarily Submitted Information:
Information such as your name, address, phone number, and email address if you provide it to us. For instance, you might provide us this information to register for an event, to obtain information about our services, to download datasheet/ user-manual or to set up an account
on our system (in which case you might provide additional information to us, such as about your employer or in some cases, your payment information). You may opt-out of this type of collection by emailing us with the subject: Opt-Out.
b. Device or Browser-based Information:
Information from your desktop computer, laptop, mobile phone, tablet, or other consumer electronic devices that you use to access the Site. This may include technical information about your Device (such as the Device type, operating system, settings, and system configurations, IP address, Advertising ID and other unique Device identifiers, and mobile network information) and your activity using the Site (such as data about the webpages you access, traffic to and from websites, the dates and times associated with transactions, web log data, and other event information, including crashes and system activity). You may opt-out of this type of collection by adjusting your device or browser’s sharing settings to limit such sharing.
We and our service providers may place cookies on our Visitors’ browsers. You may opt-out of this type of retargeting and other types of interest-based advertising by exercising the opt-out choices described in Section 6.
If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies via your browser settings. Like most websites, if you turn your cookies off, some of our services may not function properly. However, you can still place orders over the telephone or by contacting customer service.
d. Web Beacons
Web beacons or “pixels” are electronic images that may be used on the Site 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. You may opt-out of this type of retargeting and other types of interest-based advertising by exercising the opt-out choices described in Section 6.
3. How Do We Use the Information We Collect from Our Services?
When you share data with us, both NybSys and our Trusted Partners may use the data collected for any of the following purposes:
a. Inferences from Aggregated Data, such as Traffic Patterns and Research:
- Aggregated Traffic Patterns: We use the information we collect and receive to make inferences about human location and traffic patterns. For instance, we might notice groups of Devices at certain types of locations or venues over time, like concerts, soccer or baseball stadiums, cafes or gyms and spas, and we might include these observations in the services.
- Data Products: We curate these insights into data products which we provide to our Trusted Partners. We may append other fields such as venue name, category, dwell timed or ticker symbols to an aggregate group of Advertising IDs to build consumer profiles or to make financial-based decisions such as trading on the stock market.
- Marketing and Research: We also share this information with Trusted Partners in the marketing and research industry, including advertising platforms, who use the information to provide similar services. The information helps these companies to better predict and draw insights about consumer, market or scientific trends related to human movement patterns.
- Smart Cities and Security: We also license the information to Trusted Partners involved with real estate, city planners or smart city companies and augment it with relevant fields to create more specific segments for their needs. We also license the information to Trusted Partners to power solutions in government planning, security, and law enforcement.
b. Interest-Based Segments and Ad Targeting:
- Interest Based-Segments: We also use these observations to categorize Device users into “interest segments” (for instance, that a device is associated with an interest in attending sporting events, or department stores) that the Trusted Partners we license information to can use to send ads to users when the same users appear on their own mobile platforms.
- Ad Targeting: By using interest segments, marketers are more likely to be able to send an offer that a consumer is more likely to want and less likely to find annoying.
- Attribution Analysis: We use some of the information we collect and receive (including location information and Advertising IDs) to help advertisers analyze aggregate ad performance – such as by measuring whether or how Devices that saw a particular ad tended to engage with a particular product or visit a particular venue; this practice is sometimes called “attribution” analysis.
d. Publisher Insights:
- Insights and Compliance: We help the Publishers that we work with understand more about the users of their own apps – using the same types of interest segments we have described above.
- We can also use that information to inform Publishers of compliance options with applicable laws and guidelines where applicable.
If you are interested in how we collect, use and share information about our own Trusted Partners and visitors to our corporate website, please go to Section 5.
4. How Do We Use the Information We Collect from Our Visitors?
We also use information we collect and receive from Visitors for corporate and internal purposes as follows:
a. Internal analytics, such as to understand what products and services Visitors may be interested in, which pages of our Site are most (and least) popular, and to help us understand how people interact with our Site in other ways. If you have provided your personal contact information to us (such as your email address), we may combine this information with the above information described in Section 2. Visitors to understand how better to serve you.
b. To communicate with Visitors directly, such as to provide customer or Visitor support for the Site or the Services. For example, when you use the “Contact Us” form of the Site or send us an email at firstname.lastname@example.org, your personal information may be processed by our system for the sole purpose of replying to your queries.
c. Market research and electronic direct marketing in accordance with applicable law.
d. Improve, operate and customize our Site.
e. For human resource purposes.
Note about personally identifiable information. In some cases, we receive information that can identify a specific person. We use this type of information for statistical, analytical, and logistical purposes and for improving the products and services we offer. We do not use this type of information for targeting advertisements (other than at an aggregated level, such as zip code), although, we do use personally identifiable information to help synchronize our data sets with our customers’ or our partners’ data sets (to find matches through a common identifier).
We do not display or target advertisements based on information or an activity that is deemed to be “sensitive” (based on local laws or applicable industry standards).
5. Who Else Do We Share Information We Collect With?
We share the data and information we compile about someone in an aggregated way or using advertising IDs or anonymous identifiers:
- to display and optimize advertisements (like improving the relevance of the advertisements displayed, tailoring them to certain interests, or creating audience segments),
- for measurement, statistics, usage reporting, and other data analytics, and
- for industry analysis, demographic profiling, market research and other such purposes.
In certain cases, we share personally identifiable information:
- when a person has given their consent to do so (like where you are notified that the information you submit will be shared in a particular way and you then provide that information),
- with service providers who help us provide our services (if it is necessary, but they are not permitted to disclose or to use that information for any other purpose),
- with our partners and customers (if it is necessary to provide our products and services (such as to match data sets) but they are not permitted to disclose or to use that information for any other purpose),
- when we believe that we are legally authorized or required to do so, or where doing so is reasonably necessary or appropriate to comply with the law or legal processes or to respond to lawful requests or legal authorities (such as a subpoena or court order),
- if it is necessary to defend or to protect our rights, property, or interests, and
in connection with a corporate transaction (like a financing, acquisition, sale of company assets, or bankruptcy) where this information would be disclosed or transferred as one of our business assets.
6. Consumer Choices & Opt-Out Options
There are several ways that you can manage the way that passively collected data, such as Advertising IDs and cookies, are used. We describe these methods below. You can manage certain collection and sharing of information in connection with the NybSys Site and the Services as follows:
a. Browser Settings: You may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser.
b. Interest-Based Advertising Opt-Out: You can opt-out of information collected for web-based interest-based advertising (for instance, by tailoring ads based on activities tracked across websites, over time), by those companies that participate in the Network Advertising Initiative or the Digital Advertising Alliance, by visiting the NAI’s opt-out page or the DAA’s Consumer Choice Page. The “opt-out” methods on these industry web portals generally are cookie-based, so if you delete your cookies (or change or update your browser) you will need to opt-out again. We provide the above information because — although our services are not focused on cookie-based advertising — we may work with companies to target ads for our own services (such as to retarget Visitors of our own website). In addition, some third-party platforms may employ our Information to connect user identities across devices – such as to inferentially “match” a mobile device by common IP address to a web browser.
c. Device-based Opt-out (for Cross-App Advertising): You may limit the disclosure of certain Information by your mobile device to us and Publishers by adjusting the settings on your mobile Device. For iOS mobile devices, go to “Settings” from your Device’s home screen; scroll down to “Privacy”; select “Advertising”; and turn on “Limit Ad Tracking.” For Android mobile devices, go to “Google Settings” on your device; select “Ads”; and check the box labeled “Opt Out of Interest-Based Ads.” For additional instructions or information about how these opt outs work, go to the NAI’s Mobile Choice page, here. We honor these “limit” or “opt-out” instructions or “flags” by removing recognized devices from our cross-app advertising or ad delivery and reporting solutions, on a going forward basis.
d. NybSys-based Opt-out: You may limit the use of certain information by submitting an opt-out request here at email@example.com.
e. Our Promotional Emails: You may opt not to receive promotional emails from us by contacting us as indicated below, or by following the “unsubscribe” instructions in any promotional email you receive from us, or by contacting us at firstname.lastname@example.org. Please note that, however, we may still send you non-promotional, transactional, or service-related emails about your relationship with us.
We employ administrative, technical, and physical safeguards for our physical facilities and in our computer systems, databases, and communications networks, which are designed to protect information contained within our systems from loss, wrongful acquisition, use, alteration or disclosure. No method of electronic transmission or storage is 100% secure, which means we cannot guarantee absolute security of your information. However, we limit access to Location Data or Advertising IDs we collect to specific employees and third parties who have a business need to know and who are bound by a duty of confidentiality. If you have any questions about the security of your information, please contact us through the contact information.
8. International Transfers
We may store and process your information in the United States. By accessing this website or our Services, you understand that the information you provide to us may be stored in or (if applicable) transferred to the United States. You should be aware that certain privacy laws in the United States and other countries regarding processing the information may be less stringent than in your country.
9. Children’s Data
Our Services are not intended for (and we do not intentionally collect data from) minors under the age of 16. If you are aware of any such data that we may have inadvertently collected or had transferred to us, please contact us at email@example.com.
10. Addendum for California Residents’ Privacy Rights
We describe in the following sections (as required by the CCPA) the information we collect and the purposes for which we may use California Consumers’ Personal Information:
- Categories of Personal Information We Collect, Use, and Share with Third Parties
- Our Business Purposes for Collecting and Sharing Personal Information
- California Privacy Rights and Choices (Section 3)
1. Categories of Personal Information We Collect, Use, and Share with Third Parties
Depending on how you interact with us, we may collect some “Personal Information” which means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. We may share the specified categories of Personal Information with our third-parties. All of the Personal Information Categories are subject to your Right to Access.
2. Our Business Purposes for Collecting and Sharing Personal Information
- Online Targeting:
a. Assisting advertisers, agencies and the platforms that they access (a) to deliver advertising and marketing to send, tailor, optimize and analyze advertising, in mobile apps and across other advertising channels and platforms and (b) to measure and analyze such advertising and marketing.
b. Assisting Clients by creating “identity” graphs, to help locate users across various channels, such as connecting identities based on common personal, device-based, or network-based identifiers (e.g., IP address, email address)
- Marketing and Other Research:
a. Providing information for research purposes related to financial and market research, traffic and city planning, smart cities, or educational purposes. We may also provide information to government agencies or health organizations interested in traffic patterns for purposes of disease prevention research, security, anti-crime and law enforcement, or civic and traffic planning.
- Operating Our Services:
a. Improving, testing, updating, and verifying our own data and data services
b. Developing new products
c. Operating, analyzing, improving, and securing our services.
- Other Internal Purposes:
a. For internal research, internal operations, auditing, detecting security incidents, debugging, short-term and transient use, quality control, and legal compliance. We use the information collected from our own website, our owned and operated mobile apps, and third party mobile apps for the above, as well as for our own marketing purposes
c. Sharing in Event of a Corporate Transaction: We may also share personal information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.
d. Sharing with Service Providers: We share any personal information we collect with our service providers, which may include (for instance) providers involved in tech or Trusted Partner support, operations, web or data hosting, billing, accounting, security, marketing, data management, validation, enhancement or hygiene, or otherwise assisting us to provide, develop, maintain and improve our services.
e. Sharing of Aggregate Information: We may aggregate and/or de-identify any information collected so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, at our
3. California Rights and Choices
While CCPA is a California Law, we are honoring the CCPA requirements for all United States Residents.
Information for California Residents
California Consumers’ Rights and Choices
If you are a California resident, California law permits you to request Information regarding the:
- Categories of Personal Information (as defined by applicable California law) collected, sold or disclosed by us;
- Purposes for which categories of Personal Information collected by us are used;
- Sources of information from which we collect Personal Information; and
- Specific pieces of Personal Information we have collected about you.
In addition, if you are a California resident you may:
- Opt-out of the sale or disclosure of your Personal Information, in some circumstances;
- Opt-out of receiving marketing communications from us; however, you may still receive administrative communications regarding the Services;
- Opt-in to certain financial incentive programs we may offer related to the collection, sale, or deletion of your Personal Information; and
- Request deletion of your Personal Information by us and our service providers, in some circumstances.
Collection and Disclosure of Personal Information from California Residents
The table below outlines how we handle personal information from California residents.
|Personal Information Collected|
|How we collect personal information||Mobile applications, Websites, Consumer Data Resellers, Business Partners|
|Categories of personal information we’ve collected in the past 12 months||Identifiers, Geolocational Data, Internet or other electronic network activity and information, Inferences drawn from Personal Information|
|Categories of personal information we sell||Identifiers, Geolocational Data, Internet or other electronic network activity and information, Inferences drawn from Personal Information|
|Categories of personal information we otherwise share||Identifiers, Geolocational Data, Internet or other electronic network activity and information, Inferences drawn from Personal Information|
We share or sell the categories of personal information listed above with the following categories of third parties:
- Advertising technology companies, such as advertising networks.
- Analytics providers.
- Consumer data resellers.
- Vendors and service providers.
- Third parties as required by law and similar disclosures.
- Third parties in connection with a merger, sale, or asset transfer.
- Other third parties for whom we have obtained your permission to disclose your personal information.
12. How to Contact Us