PRIVACY POLICY

Last updated: May 24, 2016

Definitions

The following is a non-exhaustive list of definitions of words and phrases found in this document:

“Affiliate” is an entity that Controls, is Controlled by, or is under common Control with Theory Mobile.

“Apps” include consumer mobile applications published by Theory Mobile.

“Location information” can include, for example, your device's GPS signal and information about nearby WiFi networks and cell towers.

“Personal Information” is information that identifies a specific person. It includes name, address, telephone number, email address, payment card number, and government-issued identification number.

“Non-Personally Identifiable Information” is every kind of information except for Personal Information.

“Services” include security and analysis associated to the secure transmission of data enabled by the use of Apps.

Information Collected

When you sign up for or use our Services we may ask you to provide certain Personal Information. For example, we may ask you to provide information that can be used to directly contact you - such as your name, e-mail address or phone number. If you contact us, we may keep a record of your communication and contact information.

When you use the Apps, you choose to route all of your mobile data traffic through, or to, Theory Mobile’s servers. As a result, we receive information regarding you, your online activities, and your device or browser when you use the Services. For example, we may receive:

Information about your device, including the type of device, its operating system, the mobile carrier or network, IP address, Location Information and device identifiers. When you download the Apps, you may permit us to access data on or about your device, including permissions obtained through our Apps or your device (e.g. Google Play on Android).

Information about your mobile applications and data usage, including the applications installed on your device, your use of those applications, the websites you visit, and the amount of data you use.

Log information and other data from your device, such as webpage addresses and data fields.

We may receive the content of your communications and other mobile data transactions when your mobile data is transferred through our server. We may also receive Location Information when you access location-based services on a device that uses one of our Apps. For example, if you access an online map application, we may receive location information as part of the mobile data traffic we receive when you use our Apps. While we receive this data as part of the provision of the Services, we do not log or otherwise collect the content of those communications unless we tell you about it in this Privacy Policy or with your permission.

Information about you, including Personal Information and Non-Personally Identifiable Information, from our Affiliates or third-party partners.

Use of Information

We may use the information we receive to provide, analyze, improve, and develop new and innovative services for users, Affiliates and third parties; to communicate with users; to support advertising and related activities; and to help protect ourselves or someone else. For example, Theory Mobile may use your information to:

Provide the Services, such as by compressing data and reducing your mobile data usage, monitoring active apps on your device, and encrypting data traffic;

Communicate with you, including about products, services, and events; respond when you communicate with us; and send you information you request or that we think might interest you, such as App updates;

Analyze how you use applications and data. For example, we may combine the information, including Personal Information, that you provide through your use of the Services with information about you we receive from our Affiliates or third parties for business, analytics, advertising, and other purposes;

Provide market analytics and other services to Affiliates and other third parties;

Maintain, improve or administer our Services; perform business analyses; provide advertising and related activities either independently or in connection with our Affiliates; or otherwise support our internal operations by activities such as troubleshooting, data analysis, testing, and research;

Enforce our Terms of Service; prevent unlawful activities and misuse of the Services; protect the legal rights, property, safety, and security of Theory Mobile, our Affiliates, and our users; and resolve disputes involving you relating to the Services; and

Comply with applicable laws and assist law enforcement when we have a good-faith belief that such cooperation is reasonably necessary or meets the applicable legal standards.

Information Collected by and Shared with Third Parties for Interest-Based Advertising

We work with Affiliates and third parties to collect certain Non-Personally Identifiable Information about your interests to provide targeted advertising and analytics services on our site or within our application, or across other sites and other applications.  These entities may use technologies to collect information about your use of our mobile applications, including device attributes such as:  operating system, hardware version, device settings, IP address, time zone, device carrier, applications installed on the device, and device advertising identifiers.  We may share and allow our third party partners to share this non-identifying information with other third parties that perform targeted advertising activities across other apps and websites.

Cross-Device Advertising

We may share your information, including Personal Information and Non-Personally Identifiable information with Affiliates or third parties to enable targeted, interest-based advertising across other devices and browsers that your device or browser is linked to. You may opt out of receiving cross-device advertisements. To learn more about the controls available to you and how to use them, visit http://www.theorymobile.com/opt-out.html.

Sharing Personal Information

We do not share or sell users’ Personal Information to third parties unless you give us permission to do so (including by your use of the Services as described by this Privacy Policy) or we have given you notice, such as by telling you about it in our App, or in certain other circumstances. Specifically, we may share Personal Information in the following instances:

Affiliates. We may share (or receive) information, including Personal Information, with (or from) our Affiliates (as defined above) to help provide, understand, and improve our Services (such as by providing analytics) and Affiliates' services (including by providing you with a better and more personalized experience). For example, if you have an account with an Affiliate, that Affiliate may combine Personal Information that it receives from Theory Mobile with information that it maintains about you, for purposes of delivering targeted advertising.

Service Providers. We may share your information, including Personal Information, with third parties that perform services on our behalf to help us provide, understand, or improve the Services. For example, we may use Affiliates or other partners to help host our services and databases, perform analyses or research, send communications on our behalf, or measure the effectiveness of our advertising. Our service providers agree to only use your information in accordance with our agreements with them as well as this Privacy Policy.

Other Parties When Required By Law or as Necessary to Protect the Services. We may access, use, preserve, and share your information, including Personal Information, with third parties when we have a good faith belief that it is necessary to: detect, prevent and address fraud and other illegal activity; protect ourselves, you and others, including as part of investigations; or prevent death or imminent bodily harm. We may also share such information if we believe that you have abused your rights to use the Services or violated an applicable law, or in connection with any dispute between you and us with respect to the Services.

In Response to a Legal Request. We may also access, use, preserve, and share your information, including Personal Information, in response to a legal request if we believe in good faith that the response is required by law in that jurisdiction, applies to users in that jurisdiction, and is consistent with internationally recognized standards. Information we receive about you may be accessed, processed, and retained for an extended period of time when it is the subject of a legal request or obligation, government investigation, investigation concerning possible violations of our terms or policies, or otherwise to prevent harm

In Connection With a Transfer of Assets. If we sell all or part of our business, make a sale or transfer of assets, are otherwise involved in a merger or business transfer, or in the event of bankruptcy, we may disclose and transfer Personal Information to one or more third parties as part of that transaction.

Other Disclosures. We also may disclose Personal Information as described to you at the point of collection or pursuant to your consent.

Our Services may offer publicly accessible blogs or community forums. Any information you provide in these sections will be public and may be read, collected, and used by anyone who access them.

Cookies and Similar Technologies

Cookies are small pieces of data that are stored on your mobile phone, computer, or other device. Pixels, often used in connection with cookies, are small blocks of code placed in webpages that do things like allow another server to measure how frequently webpages are viewed and used. We and our partners may use cookies, pixels or similar technologies when operating the Services. For example, we may use them to make the Services easier or faster to use; customize the Services; collect information for statistical and analytical purposes; verify information; support advertising and related activities; and for information security purposes. We may also use mobile analytics to better understand the functionality of our Apps. We may receive and store information such as how frequently our Apps are used, where they were downloaded from, the events that occur within them, and their performance data.

Your browser or device may offer you control over the use cookies or other technologies when you use the Services. For example, you may be able to set your browser or device to disable, clear, reset or block the use of cookies or similar technologies. Further, your device controls may allow you to you to opt-out of having applications collect location information about your device, or remove the VPN connection that you establish between your device and our server when you install our Apps, and through which you allow the Apps to transmit your mobile data. Using these controls may, however, complicate or prevent your use of the Services or certain features.

Third-Party Activities

Third parties such as ad networks, analytics providers, software bug tracking services, or our Affiliates may also use cookies, pixels, and similar technologies when you use our Services that help us better manage and provide content on the Services. Third parties could also use these technologies to collect information about how you use our Services and other sites. Our Website may also include features such as plug-ins or widgets operated by third parties, or contain links to third-party websites or mobile applications not owned or controlled by us. Third parties may use these features to collect information like your IP address and the pages you visit on our Website. We do not control or have access to the cookies, similar technologies, or other features used by these third parties, and their activities are covered by their own privacy policies and terms of service. We recommend that you review the privacy policy of the third-party website or service.

To learn more about the choices that advertisers provide generally for individuals to influence how information about their online activities over time and across third-party Web sites or online services is collected and used, visit the Network Advertising Initiative at http://www.networkadvertising.org/managing/opt_out.asp, the Digital Advertising Alliance at http://www.aboutads.info/, the Internet Advertising Bureau (US) at http://www.iab.net, or the Internet Advertising Bureau (EU) at http://youronlinechoices.eu/.

Choice

Using the settings we provide, including in the Apps that you install on your device, you may opt-out of certain direct marketing communications and certain ways Theory Mobile will use the information, including Personal Information, we receive when you use the Services. To learn more about the controls available to you and how to use them, visit http://www.theorymobile.com/opt-out.html.

These controls let you limit certain uses of information that we collect when you use the Services, but we will still receive information and use it as otherwise described in this Privacy Policy. For example, we will still continue to analyze your mobile data traffic to provide services and insights to you and others, as a part of our product development and other internal operations, and to help protect against malicious activities. If you do not want us to receive any information about you, then you should uninstall the Apps and stop using the Services. For more information please see “Access and Deletion” below.

Data Retention

We may retain information regarding you and your use of the Services, including Personal Information, for as long as needed to provide you with the Services and the uses described in this Privacy Policy. This often means that we will keep information for the duration of your account.

If you stop using the Services, you can request that we remove the Personal Information that we collected from you through the Services. For more information on how to do this, please see “Access and Deletion,” below.

Please note that in the course of providing the Services we collect and maintain anonymized information, which we may retain indefinitely.

Access and Deletion

You may access or request the deletion of your Personal Information that we receive through the Services by contacting us at hello@theorymobile.com. We will respond to your request within a reasonable period of time, typically 30 business days. We reserve the right to reject requests that would require an unreasonable technical effort or are unnecessarily repetitive. Theory Mobile will not delete information that we believe is necessary to comply with our legal obligations, to resolve disputes, or to enforce our agreements. If you no longer consent to our receipt of information through your use of our Apps, or to stop using the Services, you can uninstall the Apps.

To request the removal of your Personal Information from our blog or community forum, contact us at hello@theorymobile.com. We will advise you if for any reason we are not able to accommodate your request.

Security

We maintain adequate safeguards to help protect against loss, misuse, unauthorized access, disclosure, alteration, or destruction of the information we receive. While we strive to protect your information and privacy, no data transmission or storage can be guaranteed to be 100% secure. We cannot guarantee or warrant the security of information you disclose or transmit to us and cannot be responsible for the theft, destruction, misuse, unauthorized access, alteration, or inadvertent disclosure of your information.

International Transfers

We may store and process your information through third-party or Affiliate hosting services in the United States, European Economic Area (“EEA”), and other international jurisdictions. As a result, we may transfer your information, including Personal Information, to a jurisdiction with different data protection laws than your jurisdiction. By using the Services, you explicitly and unambiguously consent to the transfer of your information internationally, including but not limited to the United States, for the purposes described in this Privacy Policy.

Children’s Privacy

If you are under 13, you may not use any of the Services. The Services are not intended for use by, or directed to, persons under the age of 13 and we do not knowingly collect Personal Information from such persons.

Your California Privacy Rights

California law permits residents of California to request certain details about what Personal Information a company shares with third parties for the third parties' direct marketing purposes. Theory Mobile does not share your Personal Information with third parties for the third parties’ own and independent direct marketing purposes unless we receive your permission. If you have questions about our sharing practices or your rights under California law, please write us at hello@theorymobile.com.

Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes in our privacy practices. If we make any material changes, we may notify you by contacting you through our services, emailing you (to the address specified in your account, if we have an address for you), or by posting a notice on the Apps or our Website – or by some combination of these methods. We encourage you to periodically review the Website for the latest information on our privacy practices.