The data used for the purpose of delivering business services is sourced through our Partners. We do not collect data directly through our own mobile apps or websites.

The data types and fields, which we collect are as follows:

• Device Fields - Advertising ID and Type, Device Make, Device Model, Device Version, Device Language, Device Resolution, OS, OS Version, Connection Type, Carrier, Limit AD Tracking Flag, User Agent.
• Location Fields - Latitude, Longitude, Horizontal Accuracy, Altitude, Vertical Accuracy, Speed, Course / Bearing, IP Address, Location Context (Foreground / Background), Location Method.
• App Usage Fields - Timestamp, App Name or Bundle ID.
• Demographic Fields - Timestamp, Gender, Year-of-Birth.

We do not collect any data from users in European Economic Area (EEA) or European Union (EU) countries. We do not collect data that can be directly used to identify you, such as your name, mobile phone number, your email address, etc.

Data Usage by ModFx for Providing Services

We use the collected data for one or more of the following purposes:

• Targeted Advertising: Data is shared with Advertisers to enable them to run Targeted Advertising Campaigns and measure their effectiveness.
• Content Personalization: Data is provided to Customers who use it to personalize content and experience for individial users.
• Retail Trends Analysis: Data is offered to Customers who use it to analyze performance of retail stores and businesses.
• City & Traffic Planning: Data is supplied to city and traffic planning bodies to help them plan city infrastructure.
• Financial Modeling: Data is given to Customers who use it to project financial results including revenue numbers and growth.
• 3rd Parties: We enter into relationships with other 3rd Party Businesses, which may help us provide data to their Clients (end-Clients). These end-Clients may use the data for any of the above mentioned purposes.

Options for End-Users

Here are the various options available for End-Users:

• Privacy Policies: The End Users should comprehensively go through the privacy policy of any application that they intend to download or have already downloaded. In case, the data collection approach and policy does not provide you the desired comfort level, you should not download the application or should remove already downloaded application.
• Device Settings: For most operating systems, the end-users can choose to control the data types collected through mobile applications. The end users can modify the device settings based on the specific instructions provided by the OS for limiting the data collection by applications.
• For data being collected through Bluetooth, the end-users can opt to disable Bluetooth through device settings.

Disclosure to 3rd Parties

The data that we collect from the Partners may be disclosed to certain 3rd parties, wherever we may enter into specific business contracts, only with the purpose of servicing the terms of such contracts. Outside of the direct disclosures while delivering business services, we may also have to disclose data with certain other entities, such as data warehousing, other support service providers and law enforcement agencies, wherever essential.

Children Privacy

We or our partners do not collect information from children under the age of 16. If you believe we have collected Information from a person under the age of 16, please contact us.

Below are step-wise instructions for opting out:

• Figure out your Advertising ID:
  • On iOS: Go to Settings > General > About
  • On Android: Go to Settings > Ads
• Option-1: Fill out and submit below form:
  Submit   
• Option-2: Send an email to opt.out@modfxlabs.com with subject “ModFx Labs - Opt-Out Request {your Advertising ID}”.
• If your Advertising ID is a part of our data records, we will block the same within 10 working days. This will ensure that ModFx will stop using your Advertising ID in any of our business services and further disclosures to our Customers or any other 3rd Parties.

Procedure to Limit Collection of Mobile Data

If you wish to limit data from being collected from your mobile device in the future, you can limit ad tracking on your device. The instructions below are current as of the most recent update of this Privacy Policy but are subject to change at any time by device manufacturers. The NAI maintains a guide showing how to opt out on a variety of mobile devices: http://www.networkadvertising.org/mobile-choice.

If you use multiple devices we will opt out those devices that we have linked to the Advertising ID that you provide when opting out. Since we may not have all your devices connected back to your user, you may need to execute this opt-out on each device.

To opt out of receiving targeted ads that are based on your behavior across different mobile applications follow the instructions below, for iOS and Android devices:

• On an Apple device, go to Settings / Privacy / Advertising. You can turn on “Limit Ad Tracking”, which will prevent advertisers from collecting your mobile ad identifier. You can also reset your ad identifier, which will disconnect your mobile device from any information previously connected.
• On an Android device, go to Settings / Google / Ads. You can turn on “Opt out of Ads Personalization”, which will prevent the use of your mobile ad ID for advertising.

Statistics of Opt-Out Requests

Here is a compiled list of number of requests to delete, to know, to access, to opt-out of sale or sharing, or to limit the use of a consumer’s personal information that ModFx received, complied with in whole or in part, and denied during the previous calendar year AND information of the median and the mean number of days within which ModFx substantively responded to requests to delete, to know, to access, to opt-out of sale or sharing, or to limit the use of a consumer’s personal information that ModFx received during the previous calendar year:

• No of Requests to Delete: 24
• No of Requests to Know: 15
• No of Requests to Opt-Out: 22
• Mean Days to Respond: 3
• Median Days to Respond: 3

Retention of Partner Data by ModFx in Terms of Duration

ModFx retains the collected data for a period of 3 months from the time of collection. Such collected data includes Device Fields, Location Fields, App Usage Fields and Demographic Fields as described in an earlier section.

Information Security

ModFx protects information in it's possession against unauthorized access, disclosure, alteration, or destruction. We regularly review our physical security, storage, and processing to ensure compliance with industry best practices. However, as no physical or technological safeguards are 100 percent secure, we do not guarantee the security of any particular elements of data that we hold.

GDPR

ModFx does not offer a product or services directed or relating to activity in EEA countries and does not intend to collect data with respect to activity in EEA countries. We likewise ask data providers that we deal with not to provide us with data relating to user activity in EEA countries. Should we receive any such data, we delete it on a timed basis, and do not intentionally employ it in our products or services. Further, should any of the foregoing change, we will update this section of our Privacy Policy.

Modifications to Privacy Statement

ModFx reserves the right to modify this statement whenever we believe it is appropriate to make such modifications. We suggest that you review this statement periodically after checking the last updated date (mentioned on top of the statement).

Queries and Clarifications

Feel free to contact us at connect@modfxlabs.com for any queries and clarifications with regards to this Statement or any such concern that may be related to your privacy. We will be happy to connect with you.