Privacy is a key element of Parousya core business. Parousya follows the principle of ‘privacy by design’. This means the Parousya Automatic Check In Service (ACIS) has been designed from the ground up to lead the industry on privacy.
Unlike location services platforms, Parousya’s ACIS (Automatic Check In System) doesn’t track end users or collect their personally identifiable information. All data is anonymised, so end-users can’t be identified.
Parousya actively seeks to protect the privacy and data of individual end users of mobile applications (“End Users”). To this end, we have implemented a range of privacy safeguards (outlined below) as core elements in the design, development and operation of the Software, Services and Site.
Our Software, Services and Site have been designed so that we do not collect any personally identifiable information about the End User or track the movement of the End User.
Our clients and partners are entities or individuals, such as companies or application developers, that use the Software, Services and Site to develop, distribute and manage location-based platforms and mobile applications. Our Clients are not the End Users. We, however, recognize, respect and actively seek to protect the End User’s privacy.
“Privacy by Design” to protect the privacy of End Users
Parousya has structured its data collection and storage model to ensure that the privacy and data protection of End Users are considered core objectives, with safeguards integrated in the design and development of a technology or product, rather than being applied after development is complete.
As a result, our data collection and storage model has been designed so that we do not collect any personally identifiable information about, or track the movement of, the End User.
When an End User begins using an application that contains or connects to Parousya Software or Services, a randomized unique reference number (“Install Reference”) is issued to that particular instance of the downloaded application. The Install Reference is not connected to the personal information of an End User or their device.
If an End User is using multiple applications that use Parousya Software or Services on the same device, then multiple, distinct, random Install References will be issued to ensure that the End User cannot be identified by associating the multiple applications they are using with a single overarching ID or reference number.
We do not combine datasets for multiple Install References in order to prevent inferences or patterns emerging that could directly or indirectly identify an End User.
We do not continuously, periodically or intermittently track an identifiable End User or record their precise or general location.
The location of a device with a random Install Reference is identified when that device performs an Action (e.g. sends a notification or plays a tone) upon its entry into a geographic area (known as a ‘Zone’, which comprises one or multiple related Geofences, Geolines or Beacons) that has been pre-defined by the Client or Partner for use in an application.
The Client or Partner may also set particular Conditions that must be met for an Action to be triggered (e.g. entry into a Zone by the End User within a pre-defined date and time range). We record the following data from the device at the point an Action is initiated:
- randomized Installation Reference associated with a particular instance of a downloaded application;
- geographic coordinates (usually longitude and latitude) associated with the location where the action was initiated;
- estimated accuracy with which the device is being located;
- date and time the action was initiated;
- make and model of the device;
- software platform (Android or iOS) and version of the operating system on the device;
Once this final stage of anonymisation has been carried out, the data is passed on to a separate analytics platform and all data that was originally recorded is permanently deleted from the servers that are not used for analytics.
The Client and Partners (not End User) information we receive or collect
You may browse the Site without a Parousya account, but an account must be created to use the Software or Services. We may collect the following information from our Clients and Partners (not the End User) when they create a Parousya account:
- legal name of the Client or Partner, such as the registered name of the entity that owns the application;
- name and contact information of the representative acting on behalf of the Client or Partner;
- email address and password to access the Parousya account; and
- industry, size, intended use of the Software and Service and other similar information.
The Client or Partner’s user name, password and Application ID created or issued during the registration process may be requested when logging in subsequently.
We reserve the right to periodically contact our Clients or Partners to confirm that the information held is correct and up to date.
What Is a Cookie?
Yes. Parousya does use first party cookies BUT not third-party cookies, in combination with pixels, local storage objects, and similar devices (collectively known as “cookies”).
We do this to distinguish you from other users and to help us provide you with a good experience, improve our service.
Visitors to the Site
By using our Sites or Services, You agree that we may collect cookies or other general information, such as the number of views and the length of time spent on the Site by visitors, in order to optimize the Site or Services and enhance Your experience using our Site or Services.
You consent to the placement of cookies on your browser by us and our third-party service providers.
Withdraw Your Consent at Any Time
If you do not wish to accept cookies in connection with your use of the Site, you will need to delete and block or disable cookies via your browser settings (see below).
Please note that disabling cookies will affect the functionality of the Site, and it may prevent you from being able to access certain features on the Site.
Changing Your Cookie Settings
The browser settings for changing your cookie settings are usually found in the “options” or “preferences” menu of your internet browser. In order to understand these settings, the following links may be helpful. Otherwise, you should use the “Help” option in your internet browser for more details.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.
For more information about advertising and tracking online, visit the Network Advertising Initiative. This website allows consumers in the United States of America to “opt out” of the behavioural advertising delivered by member companies.
How we use the Client and Partner (not End User) information we receive or
We use the Client and Partner information referred to above for the following purposes:
- provide, operate and maintain the Software, Services and Site;
- communicate with You about Your account or respond to Your requests or enquiries, tailor the information we send or display to You, and for similar service purposes;
- generate aggregate and anonymous reports for You about the usage of the Software and Services in or by Your application;
- process and issue bills, and charge payments for use of the Software and Service;
- provide You with information about our company or products that we believe may be of interest, including by sending promotional e-mails (from which You may opt out); and
- to improve the design and delivery of, and better understand how You use, our Software, Services and Site.
How we disclose Client and Partner (not End User) information
We will only disclose the Client and Partner information we collect or receive through our Software, Services and Site in the following instances:
- if required by law, legal process, governmental entity or other relevant authority;
- in the event of the sale or dissolution (bankruptcy) of assets, in whole or in part, of Parousya or any of its affiliates;
- to our contractors or service providers to the extent required to provide services or perform functions on our behalf;
We may share aggregate and/or non-personally identifiable information with third parties for marketing, research or other similar purposes. We will not disclose the personally identifiable information of Clients and Partners to third parties for such purposes without Your consent.
Personal identifiable information on End Users is not collected by Parousya and will therefore not be disclosed, including for any of the above purposes.
We may send You emails from time-to-time about information that we believe may be of interest to You, including news, special offers or information about products or services. You may opt-out from receiving promotional emails at any time by following the link and instructions contained in these emails, or by requesting that such emails no longer be sent to You at firstname.lastname@example.org.
Please note that it may take up to 10 business days for us to process opt-out requests. If You opt-out of receiving promotional emails, we may still send You e-mails about Your account or the Software and Services You use, or for other service purposes.
Consent to transfer information
If You are located outside of the Australia, please note that the Client and Partner information we collect or receive may be transferred to and processed in Australia. By using our Site and Services, You consent to the transfer and processing of Your information in Australia. Please note, Australian data protection laws may not provide the same level of protection as other jurisdictions, such as the European Union. Your consent is voluntary. If, however, You do not consent, we will not be able to provide You with our Software or Services.
Parousya takes the security of Client and Partner data seriously. We use a range of physical, technical and operational measures to secure the data we collect or receive from loss, misuse and unauthorized access, disclosure, alteration, and destruction, including, where appropriate, through password protection, encryption, and SSL.
Parousya stores all Client and Partner-specific information, including usage data related to Parousya accounts, within a secure hosted solution supplied by Amazon Web Services (AWS).
Please be aware that despite our best efforts, we cannot and do not guarantee the complete privacy, security, integrity or authenticity of information. The Internet provides the opportunity for unauthorized third parties to circumvent safeguards and illegally gain access to information.
Although no data transmission can be guaranteed to be 100% secure, we take reasonable steps to protect all Personal Information. Parousya maintains strict administrative, technical, and physical procedures to protect information stored in our servers, which are located in the United States and Australia. Access to information is limited (through user/password credentials and software systems) to those employees who require it to perform their job functions. We use industry-standard Secure Socket Layer (SSL) encryption technology to safeguard the account registration process and sign-up information. Other security safeguards include but are not limited to data encryption, firewalls, and physical access controls to building and files.
GDPR SPECIFIC REQUIREMENTS
Parousya customers, the ‘Data Controllers’ under GDPR, are responsible for the data rights of their end users (‘Data Subjects’) in the handling of their data.
Data Subject Rights
Parousya is committed to make available methods for our customers to address GDPR requirements. The below is intended for Parousya’s customers to take action upon receiving your end users consent settings.
Data Subjects (“subject” being the term for end users) can request the Data Controller to stop processing data.
As the Data Controller, data collection originates from integrating the Parousya SDK into your mobile apps. The first step the SDK performs is authenticating your app using a Parousya service. The app may explicitly stop the Parousya service at any time, therefore immediately ceasing data collection.
See developer documentation for Android and iOS to disable the Parousya service.
Upon an app restarting, the Parousya service should not be initiated for users whom have not consented to data collection.
In certain cases, Data Subjects may submit a request to the Data Controller to have their known data exported, in compliance with the consumer’s rights in regard to Parousya’s data collection. To make a request follow the contact guidelines below.
Parousya’s device identifier is known as an Install Reference. Data Controllers can retrieve IDs for any devices that have opted out of data collection. To make a request, send a list of all install references in a flat file to email@example.com. Parousya will then send the Data Controller company two files in JSON format, one for Rule Request logs and the other for Checkin/Checkout logs.
Right to Erasure
Known as “the right to be forgotten,” this right empowers Data Subjects to request that a Data Controller delete or remove their personal data.
Parousya shall delete Customer Data known as an install reference. Data Controllers can retrieve the IDs on devices that have opted out and made this request. To request a deletion, send Install References in a flat file to firstname.lastname@example.org. Parousya will confirm receipt of the request and notify Data Controller upon completion within 90 days.
Additionally, within ninety (90) days of termination or expiration of the Data Controller’s agreement with Parousya, all Customer Data shall be removed.
How You can access, correct or delete Your information
You have the right to access; correct or request the deletion of information we hold about You. Such requests can also be made in writing to email@example.com or by post to Suite 2, Level 1, 204 Dryburgh Street North Melbourne, Victoria, Australia, 3051. We will endeavour to respond to any requests within 10 working days of receipt of the request.
Relevant Children’s Online Privacy Protection Legislation
Our Website and Services are directed to the general public. We do not knowingly collect information from children under 13 years of age or have any reasonable grounds for believing that children under the age of 13 are accessing our Website or using our Services. If we learn that we have inadvertently collected Personal Information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under age 13, please contact us.
Other relevant Legislation:
Parousya complies with the provisions of the Privacy Act 1988 (Cth) (including the National Privacy Principles) (the Privacy Act) in Australia.
How to contact us and the dispute resolution process
Should we not handle your complaint in a satisfactory manner, the complaint may be passed on to the relevant Victorian Government (Australia) corporate dispute resolution program for mediation.
If a resolution is not achieved, the complaint is governed by the laws in the State of Victoria in the Commonwealth of Australia.
Date Last Updated 14 September 2018