Skyhook Privacy Policy

Effective Date: 06/22/2016

Skyhook Wireless, Inc. (“Skyhook”) values the personal privacy of its users, partners and prospects and is committed to maintaining that privacy and trust. This Privacy Policy explains how Skyhook collects and uses information through our location and context-enabling technology (the “Services”), as well as how Skyhook uses, stores and discloses information that is collected through our Websites (www.skyhook.com and www.skyhookwireless.com) and the My.Skyhook customer portal (my.skyhookwireless.com).

Skyhook is a member of the Network Advertising Initiative (NAI) and complies with the NAI Code of Conduct, including its requirements as to transparency, notice and user control.  In addition, as described below, Skyhook complies with the U.S. – E.U. Safe Harbor framework and the U.S. - Swiss Safe Harbor framework  regarding the collection, use, and retention of personal data from EU member countries and Switzerland.

This Privacy Policy applies only to Skyhook, and not to any applications or devices that may use our Services. Please refer to the privacy policies of each application or device to understand their privacy and data collection practices.

1. Overview of the Skyhook Services

Location Determination: Skyhook offers a software (SDK) and cloud-based (API) technology platform that may be used to calculate the approximate geographic location of a device. See http://www.skyhookwireless.com/products/precision-location. The Skyhook geolocation technology determines the location of a device by interfacing with Global Navigation Satellite Systems (such as GPS), utilizing the IP address of the device, and by scanning for nearby Wi-Fi access points and cell towers visible to the device.  This information is then processed on the device or on Skyhook’s servers to calculate and return the approximate geolocation (i.e., latitude/longitude) of the device.

Geofencing: Skyhook also offers on-device software that may be used to determine a device’s proximity to nearby points of interest, or whether a device has entered or exited a pre-defined geographic perimeter. See http://www.skyhookwireless.com/products/context-accelerator. For example, an application developer may use Skyhook software to understand when a user is in proximity of a coffee shop, in order to deliver a relevant coupon, advertisement or different user experience.

Location-Based Personas and Attribution: Skyhook also offers data services to application developers, publishers, and advertisers that segment the interests or demographics of device users into defined profiles based on anonymous geolocation data. See http://www.skyhookwireless.com/products/personas-for-adtech. The Skyhook technology will infer demographic information (such as gender, age, etc.) based on a device user’s presumed home census block and will infer interests and behaviors (apparel shopper, coffee drinker, business traveler) based on the venues a user visits over time. For example, if geolocation data collected or received from a partner suggests that a device has visited multiple auto dealerships in the past month, the Skyhook technology may characterize the device user as an auto buying intender. This information may be used to help partners better understand their users, to target users with more relevant experiences or advertisements, and to measure the efficacy of advertising campaigns or offers.

2. Information Collection by the Skyhook Services

Location Information:  When Skyhook’s geolocation platform is requested to provide a location result (e.g., to calculate a latitude/longitude), we may collect radio signal information that is provided or generated, including for example, location results, GPS coordinates, the MAC address of wireless routers (an alphanumeric code that is unique to that hardware device), the Received Signal Strength Indicator (a measurement of the strength of the access point’s signal at the time it is received by the mobile device), the cell ID of nearby cell towers, the IP address of the requesting device, UUID’s and Received Signal Strength Indicator for Bluetooth and associated Bluetooth data. When available, the Skyhook technology may also collect information about the device manufacturer, model, OS, version, and SDK version. 

All geolocation data is collected anonymously in a form that does not personally identify or track a user. In some cases, a third party application may also allow users to elect to determine the device’s location to a greater degree of precision by entering a street address. The street address is not linked to a device or a user.

For Context-Enabled Devices:  In implementations of the Skyhook technology that include our geofencing and personification services, in addition to the geolocation information above, Skyhook may also collect other attributes and information about the device, including:

  • a unique identifier or device ID (IDFA for iOS, Android ID for Android devices or a hashed partner ID that may specified and passed to Skyhook;
  • the time that a device is detected at a given location;
  • information about the device, including the device manufacturer, model, platform or operating system, time zone, network status (connected to Wi-Fi, etc.), timestamp and other similar information;
  • additional sensor information such as barometric pressure, accelerometer measurements, gyroscope measurements, device orientation, magnetic field measurements, direction of travel, motion activity (e.g. walking), or other similar sensor measurements;
  • information about the version and use of the Skyhook technology.

Information from Partners: From time to time, Skyhook may also receive information from our partners, which are usually mobile advertising networks and application developers/publishers. These partners may deliver advertising onto your mobile device and, through them, we may receive geolocation information (latitude/longitude) obtained from advertising impressions, including a unique identifier or device ID (IDFA for iOS, the Android ID for Android devices or a hashed partner ID), a time stamp, and in some cases, an IP address.

3. How Skyhook Uses Information

In general, Skyhook uses the information collected in order to operate, maintain and deliver our Services. In particular, with respect to de-identified geolocation signal information (such as Wi-Fi access point data and cell tower data that is not associated with any particular device ID), we may use such information:

  • To provide location-enabling service(s) by calculating and providing geographic location to application developers, device makers and operating systems, when users are opted in;
  • To improve the quality, accuracy and precision of Skyhook’s location database by adding the estimated location of new access points or cell towers or refining the estimated positions of existing access points or cell towers;
  • To aggregate geolocation data in an anonymous, de-identified manner in order to provide Skyhook and our partners with insights into the number and frequency of location requests in a particular area during a particular time interval; and
  • To approximate the geographic location where IP addresses are used for use in developing and marketing an IP geolocation services to partners, including publishers, data exchanges and advertising companies;

When geolocation information (i.e., a latitude/longitude) is associated with a particular unique identifier or Device ID and time information, Skyhook may also use the collected information:

  • To infer that a user is nearby, approaching or inside a particular venue or point of interest, which may be used by our partners to provide more relevant content, advertising and user experiences, as well as for analytics, attribution and reporting purposes;
  • To build anonymous location-based audience segments that infer demographic attributes and behavioral interests and activities in order to enable our partners to provide more relevant content and advertising, and for analytics and reporting purposes.

4. Opt Out Choices

Skyhook requires all clients and third parties using the Skyhook location and context services to provide notice regarding data collection and use, and to obtain all consents or permissions required, including without limitation any data such party collects, uses, and/or discloses from its users, the provision of such data to Skyhook, and the other party’s use of such data.

Skyhook also provides users to directly opt-out from Skyhook’s services as follows:

Location Information: For users who do not want any location data to be collected, the application, device, or operating system provides controls for disabling all location services.  This choice may limit the functionality of the device or installed applications

Device ID: If you wish to opt out of the Skyhook’s use of your Device ID to assist our partners with identifying your demographic information and interest segments for purposes of providing you with targeted ads, you may opt-out by clicking here. If you choose to opt out your Device ID(s), Skyhook will delete any collected data about this Device ID from Skyhook database, and quarantine the device ID so that Skyhook does not collect any data about this Device ID in the future or return or share any information about the Device ID to API or SDK requests.  

Skyhook also respects platform-level controls and restrictions, so that if you disable targeted advertising through controls offered by the application and/or through the iOS or Android “Limit Ad Tracking” or “Opt out of interest-based advertising” settings, we will abide fully by those setting. More information on how to access these settings is provided on the Skyhook opt out page, which can be accessed by clicking here. If a user chooses the “Limit Ad Tracking” or “Opt out of interest-based advertising” settings on iOS or Android, Skyhook will quarantine the device ID so that Skyhook does not collect any data about this device ID and will not return or share any information about the Device ID in response to API or SDK requests, instead returning an error code when the device ID has been opted out. Skyhook will also delete any encrypted device identified data from the opted-out user’s device.  

MAC Addresses: If you wish to opt out of Skyhook’s use of your MAC address to provide location, you may opt-out by clicking here. If you choose to opt out, Skyhook will (if applicable) delete the positioned record for that MAC address from the Skyhook database and will blacklist that MAC address so that we will not process or use that MAC address information in the future.

IP Addresses: If you wish to opt out of Skyhook’s use of your IP Address, you may opt-out by clicking here. If you choose to opt out, Skyhook will (if applicable) remove the positioned record for that IP address from the Skyhook database and will blacklist that IP address so that we will not process or use that IP address information in the future.

5. Data Retention and Data Security

Data on Device Skyhook may store an encrypted local cache of all Wi-Fi access points and cell towers in a surrounding area on the device to allow the device’s location to be determined without connecting to our servers.  A temporary encrypted history of scanned Wi-Fi access points and cell towers nearby may also be kept in memory on the user’s device and later transmitted to our servers. A maximum of 100 historic scans will be retained on device. This encrypted cache information will be deleted from the device the next time the Skyhook technology connects to the Skyhook servers, when the application terminates, or when the device is turned off.

Data Retention:  For all device identified data (i.e., location history that is associated with a unique Device ID), Skyhook will retain such data for up to twelve (12) months. After that time, some of the information we have (such as anonymous location logs) may be aggregated and anonymized for statistical purposes and stored indefinitely. Other anonymous location data that is not associated with any unique identifier, device ID or any other personally identifiable information may be stored indefinitely and used for purposes of improving and maintaining our location service.

Data Security: Skyhook is committed to protecting the security of information that is collected by its technology. We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee the absolute security of all information.

6. Website Information

This Section discusses the data practices and policies applicable to our web properties, which include www.skyhook.com, www.skyhookwireless.com and my.skyhookwireless.com.

A. Information Collection

As part of operating our Websites and My.Skyhook portal, we collect the following information:

  • Information Provided To Us: In order to access some Skyhook services, such as the My.Skyhook portal, users will be asked to sign up and provide Skyhook with a name, e-mail address and password, all of which we associate with a user’s Skyhook account.
  • IP Address and Other Standard Information: Like most other websites, Skyhook (or its web analytics partners such as Hubspot and Google Analytics) may gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.       We may combine this automatically collected log information with other information we collect about users. We do this to improve services we offer users and to improve marketing, analytics, or site functionality and to analyzing trends and gather demographic information about our user base as a whole. We may also receive reports based on the use of these technologies by our web analytics partners on an individual as well as aggregated basis.
  • Tracking Technologies (such as cookies and web beacons): Skyhook or its web analytics partners (such as Hubspot and Google Analytics) also use tracking technologies, known as cookies and web beacons, to gather information about visits to our Website and My.Skyhook portal – for example, the number of visits, average time spent, pages viewed, navigation history through the website, and other statistics. Cookies are small text files that are stored on a user’s internet browser, which can be accessed by web servers when the browser returns to this website. Users have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but users can usually modify your browser setting to decline cookies if you prefer. If you choose to accept cookies, users also have the ability to later delete cookies that have been accepted.
  • Social Media Features: Our Websites may link to our external Social Media sites or may include Social Media Features, such as the Facebook Like button. These Features may collect IP address, which page users are visiting on our site, and may set a cookie to enable the Feature to function properly. Where used, Social Media Features are either hosted by a third party or hosted directly on our websites and any interactions with these Features are governed by the privacy policy of the company providing it.

B. Use of Information

Skyhook may use the information it collects on its web properties to:

  • Assess the needs of a user’s business to determine suitable products;
  • Send users requested product or service information;
  • Respond to customer service requests;
  • Administer accounts;
  • Send marketing communications
  • Improve our services, our website and marketing efforts
  • Display content based upon users’ interests.

C. User Access and Choice

  • In the event that a user signed up for the My.Skyhook portal with an e-mail address, we may send e-mail communications to that user e-mail. At any time, a user can opt out of marketing email communications we send through a link at the bottom of each email.
  • If a user’s personal information changes, or if the user no longer desire our service, the user may update or delete your account by making the change on your Portal page or by emailing our Customer Support at support@skyhookwireless.com or by contacting us by telephone or postal mail at the contact information listed below. We will respond to all requests to access within 30 days.
  • We will retain user information for as long as an account is active or as needed to provide you services. We will retain and use user information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

D. Links to Third Party Sites

Our Websites may include links to other web properties whose privacy practices may differ from those of Skyhook. If a user submits personal information to any of those sites, a user’s information is governed by their privacy policies. We encourage all users to carefully read the privacy policy of any website that they visit.

E. Blog

The Skyhook Website offers publicly accessible blogs. Users should be aware that any information provided in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog, contact us at support@skyhookwireless.com.

7. How Skyhook May Share All Information

Section 3 above described the ways in which Skyhook uses information collected by our products to create, enhance, deliver, market and sell our services. In addition to those uses described above, Skyhook may share all information that we collect:

  • With agents, vendors or service providers that help Skyhook to process the data or operate our business;
  • As required by law, such as to comply with a subpoena, or similar legal process;
  • When Skyhook believes in good faith that disclosure is necessary to protect our legal and contractual rights or the safety of others, investigate fraud, or respond to a government request;
  • If Skyhook is involved in a merger, acquisition, or sale of all or a portion of our assets, in which case users will be notified via a prominent notice on our Web site of any change in ownership or uses of the information; or
  • Where you have granted us permission.

Except as described in this Privacy Policy, Skyhook will not share any information that is collected by the Skyhook services with third parties.

8. Children's Privacy

The Skyhook technology, services and website are not developed or intended for persons under 13 years of age. We do not knowingly solicit or collect any personally identifiable information including from children under the age of 13, nor do we knowingly market our Services to children under the age of 13.

9. Cross Border Transfers

The information we collect is stored and processed on servers located in the United States.  We may transfer information that is collected to affiliated entities, or to other third parties across borders and to other locations around the world. Use of the Skyhook technology and services constitutes consent to the transfer of the information described in this Privacy Policy to locations that may be outside of the country in which you live, and such places may be in the United States, within one or more European countries, and/or in one or more countries within Asia.

10. Safe Harbor Certified

Skyhook complies with the U.S. – E.U. Safe Harbor framework and the U.S. - Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. Skyhook has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Skyhook’s certification, please visit http://www.export.gov/safeharbor/.

11. Changes and Updates to this Privacy Policy

Skyhook may amend this Privacy Policy from time to time. When we do, we will also revise the “last updated” date at the beginning of the policy. We encourage you to review this policy periodically to stay informed about how we collect, use, and disclose data that we collect.

12. Contact Information

If you have any questions or concerns regarding privacy using the Skyhook technology, please send a detailed message to: privacy@skyhookwireless.com or contact us at the following address:

Skyhook Wireless, Inc.
41 Farnsworth St.
Boston, MA 02210
Attn: General Counsel

We will make every effort to resolve your concerns.

 

Skyhook Privacy Policy Version: 2016.3