“In Loco” - In Loco is a Brazilian technology startup which originated from research activities developed at the Federal University of Pernambuco (UFPE). UFPE is a world leading reference in the media market focusing on mobile advertisements.
We own a modern geolocation technology (“Technology”), present in internally-developed software, made available in an integrated way to third-party applications (“Partners Applications”). Through this technology, Partners Application users (“Users”) can receive personalized push notifications, according to the Partners Application requirements. It is possible because our technology collects some data such as information about the user's actual location, days of week and time, among others (In Loco Engage Push Notifications).
In Loco is used by many Partners Applications in order to increase its users engagement by sending Push Notifications In Loco Engage at the right place at the right time. Today In Loco has hundreds of partners, which you can check on our website.
In order for us at In Loco to work together with Partner Applications, allowing you to send smarter Push Notifications, some data from your mobile device is collected when you use it.
Each Partner Application shall inform you in its corresponding privacy policies what kind of data In Loco Engage may collect from your device.
In Loco always requests that all its Partners' Applications inform its users about the data that it is being collected through the application.
- Mobile Device Data
- Information about your device: the electronic advertising identifier (“advertising ID”) of the operating system (Android Advertising ID – AAID, Apple ID for Advertising – IDFA, or other), model, manufacturer, operating system, mobile carrier, mobile browser, type and speed of the Internet connection being used, IP address of the Internet connection, GMT time zone, WebView User Agent and applications installed on the device, including the identification of the applications that have the software developed by In Loco;
- Data of the sensors of WiFi, GPS, Bluetooth, accelerometer, magnetometer, gyroscope and proximity when these accesses are available in the partner's application;
- Information about the age and gender of the user.
- Country, City, State and neighbourhood;
- Estimated latitude-longitude coordinates from the workplace and housing, as well as neighbours' devices associated with these coordinates;
- Geographic data, such as climate and vegetation;
- Occupation, Education and Social Class;
- Cultural Profile;
- Age and gender;
- Means of transport;
- Internet Provider;
- How does In Loco use the data collected?
- Monitor and analyze consumer trends;
- Improve the security of the data collected and improve the services provided by In Loco;
- Identify locations on the map based on geolocation data from Users;
- Trace groups of people profiles based on socio-demographic information;
- Validation of credit card transactions for anti-fraud purposes;
- Address verification for bank account opening;
- Address verification for costumer's registration;
- Mobility data analysis for improvement in the lending process;
- Analysis of mobility data for urban planning purposes;
- Mobility data analysis for mobile media campaigns delivery;
- Mobility data analysis for understanding consumer behavior at in-store retailing;
- Mobility data analysis for planning opening of new retail stores;
- Mobility data analysis for understanding offline behavior of mobile application users;
- Sending notifications to mobile apps based on location data;
- Detection of visits to physical locations;
- Mobility data analysis for various fraud detection;
- Mobility data analysis for conducting and validating surveys.
- How we protect and store the collected and received data
- Sharing collected data with third parties
- International data transfer
- How to opt-out
When you make use of a partner application that uses our technology, In Loco may collect data about the device, including the Advertising Identifier of Android, iOS Apple (iPhone, iPad and Apple Watch), or other similar operating systems, as well as location data received from the sensors of the device. It is important to highlight that not all partners' applications collect all these data. It is important to highlight that In Loco may not collect but only receive data from your device that our Partner Applications have collected, such as information about your device activity related to their services.
We want to be clear how and what data we may collect or receive if you use one of our Partner's Application. Please find below more information about how it works.
These data, collected and received, are stored by In Loco having as the unifying basis the advertising ID from your operating system (AAID, IDFA or other), which does enable us to recognize your mobile device over time.
This is the maximum of data that we can collect from a particular advertising ID in the current technical conditions. The minimum of data that the Partners' Applications enable us to collect are related to the item A described above.
In addition to these data from your device, In Loco can also process the data gathered in order to make inferences about the location profile and interests associated with the device. Next, we detail these inference data about the advertising ID of the device:
In case of Partners' Applications that only have the minimum permissions for data collection, In Loco makes only partial data inferences about the items D and E above mentioned.
These data from your mobile device collected and processed by In Loco, do not include personal data such as your name, nor civil identifying numbers (such as Social Security), which is an asset of In Loco. Our company works with the concept of "privacy by design" dealing with the issue of privacy as a fundamental value. For that reason, we fulfil all Brazilian privacy legal requirements. Specifically, in relation to your e-mail, if you have consented specifically and unambiguously to its collection and processing for correlation and aggregation purposes with the database of some of our partners, we will only store it in the form of a hash (which cannot be understood in natural language) in order to make this data anonymous in our database.
To ensure even more your privacy, In Loco does not collect nor does any processing of data considered sensitive, such as, for example, religious and political choices, credit card data and bank data in general.
In addition to these measures, In Loco does not collect information regarding fixed hardware identifiers (like MAC - Media Access Control, or IMEI - International Mobile Equipment Identity) from your mobile device.
Therefore, the data collected does not enable us to know your identity in real life, but only to understand preferences and context as a consumer, enabling us to recognize your device over time.
Finally, it is important to clarify that In Loco does not collect any of the device data listed above when the Partner's Application is aimed at children. Thus, in case of partners' applications aimed at kids, we do not collect or make any type of processing with the device data. In addition, In Loco does not process any data, as indicated above, related to applications aimed at children under 13 years old.
When you use any of our Partner's Applications, we collect or receive data from your device. This information are stored in a database, which then may be analysed for many purposes. Technology is our competitive advantage: our location technology enables us to determine with a higher accuracy where the mobile device is or has been, sending more relevant Push In Loco Engage Notifications, at the right place at the right time.
Data from your device can only be processed, treated, stored and used for the following purposes:
In Loco may include other purposes to the above purposes by notifying the Partner Application company, in writing form, at least 30 (thirty) days in advance. This way, the Partner Applications may adapt its user's terms and conditions that regulate the licensing of use of its Platform to the User. Then, the Partner Applications may inform its Users and obtain the necessary authorization so that the Device Data may also be destined to the new purposes included by In Loco.
The safety of the data collected by In Loco is very important. This is the reason why we use security measures, such as cryptography, both on the transportation and on the storage of the data, in addition to always updating our protection system.
In Loco also performs contracts for the sharing of collected device data with some commercial partners. These shared device data have as key identifying the device advertising IDs (AAID or IDFA), or your e-mail under the above described protections.
Over and above the relationships with partners regarding the sharing of data, we would only provide collected data related to a particular device advertising ID or e-mail (if collected, with the protections described above) in the case of a specific court order and in line with the applicable legislation.
In Loco may store and process the collected device data on servers from contracted companies located in other countries, including member of the European Union or the United States. Regarding these services, In Loco will always deal with companies with a high level of information security and will establish contracts that do not violate the privacy settings provided in this policy. It is worth noting that all data stored by In Loco Media are encrypted, which guarantees a level of data security.
In Loco wants you to be clear about the ways in which you can protect your privacy. So, if you choose to do not have your data collected or received by In Loco, you may “opt-out”. To start the process of opt-out click here.
You have the right of to choose not sharing your device information. The opt-out option do not delete the In Loco's Partner's Application from your device, or have any other type of loss in the use of this application.
By opting out you will be disabling the collection and processing of data from your device for ad selection purposes done by our technology. Nevertheless, if you regret this decision, you can always reactivate our services by sending an e-mail to firstname.lastname@example.org.
However, we emphasize that the opt-out procedure of In Loco does not disable the receipt of advertising on your device. You will still receive ads, but not ads selected based on our technology. It means that the opt-out only disables the action of In Loco, so other companies may still collect data from your device. If you want to disable thoroughly the collection of device data associated with your advertising ID, you should change the settings of your device. Devices running system Android or iOS, proceed as follows:
- Select “settings” > “general” > “about” > “advertising”
- Select “limit ad tracking”
iOS 7 or higher:
- Select “settings” > “privacy” > “advertising”
- Select “limit ad tracking”
- Select “Google settings” > “ads”
- Select “opt out of Ads Personalization
If you have any questions contact us by email@example.com.