Last updated: April 18, 2014
”) when you use our service that allows you to manage third party access to and use of data relating to you and your mobile device (“Services
”), whether you access the Service via the SOLOMO website, (“Website
”) or a separate SOLOMO application, such as LIFEBOARDS, or a Subscriber application powered by SOLOMO (each, an “Application
For users choosing to sign-in to a Subscriber Application or SOLOMO Application or Website and identify themselves and/or claim their mobile devices for purposes of personalized engagement on their device, we collect information from you that you choose to disclose to us in the Subscriber Application or via your profile on lifeboards.com, SOLOMO’s end consumer site. Following completion of your registration, you may complete your data profile and choose to provide SOLOMO with as much or as little data as you wish. However, certain minimal information is required to complete your profile, which consists of your name, email address, address, cell phone number, and date of birth. Any additional information is provided solely at your option, but additional information can help our third party Subscribers, as you may permit, provide you with more targeted and customized offers and content that may be of interest to you.
Importantly, if you are present in a subscriber location utilizing SOLOMO to collect analytics, we collect information regarding your geographic location and position as part of our Services for the purpose of providing location analytics to Subscribers. SOLOMO limits the data collected for analysis to information needed to provide analytics services. SOLOMO does not share any personal information or unique device information with any Subscriber for whom you have this setting engaged, unless it is immediately de-identified.
We may obtain this information from a Subscriber that may have its own location collection service in place, through third party telecommunication carriers, wireless networks, or other third parties or through our own hardware collection devices onsite. Through our mobile platform, we will collect your location information from one of the above sources, which information will include, but not limited to, your traffic within Subscriber locations and events. At the time of collection from one of the above sources, SOLOMO takes measures to de-identify all unique device identifiers by irreversibly hashing them prior to storing them. At no time is this information stored in our platform unless specifically identified and permissioned by you,
nor does SOLOMO append
or add third party data to a user’s profile that includes a device identifier
or hashed device identifier
. This information may be collected and assembled into patterns of your activities. We use this data for our own data analysis and analytics, but will also share this information with the Subscribers that you select to access this information.
In addition, we will aggregate and de-identify geolocation information and create general analytics, which may be shared with all Subscribers regardless of your engagement setting for any particular Subscriber. Opt Out.
SOLOMO is a member a member of the Future of Privacy Forum and has committed to follow the Code of Conduct outlined for participating members. To learn about the use of customer location and your choices, visit www.smartstoreprivacy.com
. Communication Methods
We may also collect other personally identifiable information from you that you may choose to share with us in communicating with us or requesting information. We use this personally identifiable information that you may share with us in this context to communicate with you or respond to your request as applicable. Otherwise, we will only use your information for the purpose for which you disclose it. You may change your communication preferences within the Subscriber Application or SOLOMO Application or Website. Email Communications.
We collect information regarding customer activities on our Websites. This helps us to determine how best to provide useful information to customers and to understand which parts of our Websites and Services are of most interest. Member ID.
Following registration to become a Member, you will be assigned your own unique “SOLOMO ID
”, which you can use when performing various activities with respect to the Services. This SOLOMO ID will be associated with both your personally identifiable profile as well as your geolocation data and patterns collected about you through our Services. Non-Personally Identifiable Data.
We also passively collect information that is not personally identifiable when you visit our Website or Application. Cookies
As is standard practice on many websites, our Services use “cookies
Most web browsers automatically accept cookies, but you can disable this function so that your browser will not accept cookies. Please be aware that disabling this function may impact your use and enjoyment of our Services. Log Data
As is true of most online services, we gather certain information automatically and store it in log files. This information includes your Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer our Services, to track users’ movements around our Services and to gather demographic information about our user base as a whole. SOLOMO does not use the information collected to market to you. Click Through Data
In some of our email messages we use a “click-through URL” linked to content on our Services. When customers click one of these URLs, they pass through our web server before arriving at the destination web page. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked simply avoid clicking text or graphic links in the email. Aggregate Data.
The Company may take the personal information we receive from you and our other Members and combine (or aggregate) it with the responses of other Members to create broader, generic aggregate data (such as gender, age, residence, hobbies, education, employment, industry sector, or other demographic information). SOLOMO then uses the aggregated information to improve the quality of its Services, and to develop new services and products. This aggregated non-personally identifying information may be shared with third parties. Public Profile.
The information that you choose to add to your profile and permission can be read and viewed by other Members and Subscribers to the SOLOMO Services to which you have given permission. In addition, you will be able to determine which information from your profile will be publicly available to all Website users. You should carefully consider the information that you decide to add to your profile. SOLOMO is not responsible for the personally identifiable information you choose to submit or for how that information may be used by any third party, including without limitation any Subscriber. Disclosure of Your Information. Third Party Subscribers
SOLOMO may release your information to those third-party Subscribers that pay the Company a subscription fee to access your information and for whom you have permitted access to your information. We will never release your information to any third party without your permission. You may rescind permission to disclose to any Subscriber your data as collected by SOLOMO at any time. In the event that you provide your data or information directly to a Subscriber or in the event that your data is collected by a Subscriber (such as through a third party onsite geolocation service engaged by Subscriber), the collection and use of such information is outside the scope of the SOLOMO Application. Collection and use of such data by a Subscriber is solely within the Subscriber's control and SOLOMO has no responsibility or liability for any use of the same. Our Vendors
We may also disclose your information with those of our third party service providers that we use in order to provide the Services, such as our website and hosting vendors. We require these entities to maintain the confidentiality of your information and they are contractually prohibited from using your information for any purpose outside the scope of providing services to SOLOMO. Other Disclosures
We also reserve the right to disclose your personal information for any reason if, in our sole discretion, we believe that it is reasonable to do so, including law enforcement, litigation or to satisfy laws, such as the Electronic Communications Privacy Act, the Children’s Online Privacy Protection Act, regulations, or governmental or legal requests for such information. We may also disclose personal information that is necessary to identify, contact, or bring legal action against someone who may be violating our contracts, policies and procedures. Finally we may also disclose information about you if we determine that for national security, law enforcement, or other issues of public importance, disclosure is necessary. Retention of Your Personal Information
We will keep your personal information until you remove it from our systems or terminate your Membership after which point it will be permanently deleted from our active databases. Any geolocation data will be kept for twelve (12) months following any termination of your Membership. Even after any deletion of your data, we will continue to retain our data backups, which may continue to retain your data. Any such data backups will be destroyed or recycled in accordance with our internal procedures for the same. Security of Your Personal Information.
SOLOMO takes precautions—including administrative, technical, and physical measures—to safeguard your personal information against loss, theft, and misuse, as well as unauthorized access, disclosure, alteration, and destruction.
Our websites and mobile applications use Secure Sockets Layer (SSL) encryption on all web pages where personal information is required. You can help us by also taking precautions to protect your personal data when you are on the Internet. Change your passwords often using a combination of letters and numbers, and make sure you use a secure web browser.
While we make every effort to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining your personal information.
If we become aware of a security breach that impacts your information, we will notify you to the extent required by any applicable law. Integrity of Your Personal Information.
The Company has safeguards in place to keep your personal information accurate, complete, and up to date for the purposes for which it is used. After you have created an account, you always have the right to access and correct the personal information you have provided and can help us ensure that your contact information and preferences are accurate, complete, and up to date by checking your Member profile at www.lifeboards.com
, SOLOMO’s consumer identity management site. In addition, you can request a copy of your personal information, your product registration history, and your interactions with our sales and support agents by contacting us at the email address below. Privacy of Children.
Protecting children’s privacy is especially important to us. We do not knowingly collect personal information from children under 13. If a child under 13 submits personal information to the Company and we learn that that personal information is the information of a child under 13, we will attempt to delete the information as soon as possible. It is our policy to comply with the Children’s Online Privacy Protection Act of 1998 and all other applicable laws. International Users.
At this time our Services are only available within the jurisdiction of the United States of America. Visitors located outside of the U.S. are not eligible to use any of the Services offered by SOLOMO. If you are outside the United States and choose to access or use our Services, you do so at your own risk and expressly consent to the transfer of your data to SOLOMO within the United States. Links to Sites of Other Companies.
Our Services may include links to the websites of other companies. We are not responsible for the privacy practices of any such third party. We encourage you to learn about the privacy policies of those companies before you choose to disclose any information with those third parties. Further Questions Regarding Privacy.