Mira Privacy Policy

Last Updated: August 15, 2016

The Spoken Thought, Inc. (“The Spoken Thought“, “Mira,” “we” or “us”), the builder of the Mira platform, is committed to protecting your privacy. We know that you care about how information about you is used and shared, and we appreciate your trust that we will use that information carefully and sensibly in accordance with this Privacy Policy.

Please read this Privacy Policy carefully so that you understand our privacy practices. This Privacy Policy governs the personally identifiable information (“Personal Information”) collected by Mira through our websites at mira.co (the “Website”) and the non-personally identifiable information (“Non Personal Information”) or Personal Information through mobile applications using the Mira SDK (the “Mobile Product”).

Additionally, Mira collects Non Personal Information indirectly through 3rd party sources and integrations (“Third Party Sources”), such as other mobile SDKs and Mobile Advertising Exchanges (“Ad Exchanges”). The data from Third Party Sources (“Third Party Data”) is subject to terms dictated by the sources themselves, as well as terms set forth below.

Except as specifically set forth below, the terms of this Privacy Policy apply to the Websites, Mobile Product, and Third Party Data.

By visiting our Websites, you agree to the terms of this Privacy Policy with respect to your use of our Websites and any Personal Information that you may provide to us through the Website. If you are using one of our Mobile Products, whether provided directly by Mira or by one of our content partners (“Publishers”), your use of the Mobile Product will be governed by the terms of this Privacy Policy. This Privacy Policy will govern our collection, sharing and use of your Personal Information and Non Personal Information. If you do not agree to the terms of this Privacy Policy, you should not install the Mobile Product and/or should uninstall the Mobile Product immediately. Your use of the Mobile Product shall constitute your acceptance of the terms of this Privacy Policy.

Privacy of Children

Protecting the privacy of children is especially important. For that reason, Mira does not knowingly collect any Personal Information from anyone under the age of 13. In no other way do we knowingly collect or maintain personally identifiable information from persons under 13 years of age, and no part of our Website is directed to persons under 13. If Mira learns that Personal Information of persons under 13 years of age has been collected through its Website or a Mobile Product, then Mira will take the appropriate steps to delete this information.

Information Collection and Use

Website
  • Information you Provide You are not required to register or provide any Personal Information in order to browse our Website and learn more about our company, our products and our technology. We may collect Personal Information from you if you voluntarily provide us to, and it is needed to provide you a service. For example, we will collect your email address if you provide it and want to subscribe to our newsletter.

  • Browser-Level Information When you browse our Website or use any of our Mobile Products, our web server automatically collects limited information about your computer configuration or device or, such as the type of browser software you use and the operating system you’re running and your IP address.

  • Non-Personally-Identifiable Information Mira does log non-personally-identifiable information including IP address, profile information, browser type, browser language, referring / exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, from users and visitors to the Website and the type of mobile device you use, the IP address of your mobile device, your mobile operating system, and the type of mobile browsers you use. This data is used to manage our Website, including diagnosing problems with our Website, track usage and improve the Website. User IP addresses are recorded for security and monitoring purposes.

  • Cookies and Google Analytics Mira uses “cookies” to track which pages of our Website you visit. We use Google Analytics to understand how visitors interact with our Website. The type of information Google collects include pages visited, videos viewed, etc. This information helps us learn things like what pages are most attractive to our visitors, which of our products most interest our customers, and what kinds of offers our customers like to see. Because cookies are stored on your computer or device, not on our site, you can set your browser to decline cookies and can delete them from your computer or device. For more information, learn how Google uses data when you visit their partners’ sites or apps.

Mobile Products

Mira provides SDKs for each of the Android and iOS mobile operating systems (the “SDKs“ or “Mobile Products“) which collect data about mobile devices. These Mobile Products are often used via a Publisher’s own mobile properties, which act as a host for the Mobile Products. As such, use of the Mobile Products may come “indirectly“ via use of a Publisher’s own mobile product. This Privacy Policy does not govern the use by a Publisher of any Personal Information you may provide to the Publisher through our Mobile Product, the Publisher’s mobile product, or otherwise. Before sharing Personal Information with any Publisher, you should review the privacy policy of the Publisher.

  • Personally-Identifiable Information We do not collect Personal Information through our Mobile Products.

  • Automatically Collected Information; Other Non-Personally Identifiable Information When you use any of our Mobile Products, we automatically collect limited information about your computer configuration or device, such as the operating system the device is running and its IP address. Mira does log non-personally-identifiable information including IP address, profile information, browser type, browser language, platform type, domain names, the type of mobile device you use, the IP address of your mobile device, your mobile operating system, and the type of mobile browsers you use. This data is used to manage the Mobile Product, including diagnosing problems with the Mobile Product, track usage, and improve the Mobile Product.

  • Mobile Advertising Identifiers Both the Android and iOS mobile operating systems provide transient, resettable, and unique identifiers for the purposes of advertising; these are known as the Android Advertising ID and the Apple Identifier for Advertising (IDFA). Both identifiers have policies governing appropriate use, which the Mobile Products respect. The most important aspect of acceptable use of identifiers is respecting your ability to opt-out of its use. Mira collects these identifiers whenever the Mobile Products communicate with our server, if you have allowed your device to use these identifiers. These identifiers are considered not to be personally-identifiable, because they can be reset and are randomly generated.

  • Location Data By opting in to share your location data, the Mobile Product also allows us to collect information regarding your location, or the location of your device, by using GPS coordinates provided by your mobile device, or if you come within proximity of a Bluetooth Low Energy (BLE) device such as a beacon (“Location Data”). When any of our Mobile Products is open on your mobile device, we periodically receive Location Data. Most GPS-enabled mobile devices can identify a user’s location to within less than 50 feet. You can opt-out of our collection of such Location Data by turning off the GPS capability of your mobile device and rejecting our request to collect such data upon installation of the Mobile Product. If following installation of the Mobile Product, you wish to opt out of the collection of Location Data, you can change the preferences on your mobile device (by turning off the GPS capability for the Mobile Product) or by uninstalling the Mobile Product. If you choose not to permit the Mobile Product to collect such Location Data, certain of the Publisher’s services may not be available to you. Mira stores Location Data, and Location Data is passed through to the service providers and partners, including ad networks, ad serving companies and third party information providers, as described below. It is important to note that location data is not mappable to any personally-identifiable information in the manner that we collect it.

  • Aggregate Information Used to Serve and Target Ads We may aggregate the information we collect from users of our Mobile Products and use this to target ads on digital out-of-home screens. Additionally, we may use information we collect from users of our Mobile Products to obtain consumer data (Third Party Data) from third parties (Third Party Data Providers); this is described in the next section. When we aggregate your information, no specific personal information is included, and you cannot be identified from this aggregate information.

  • Aggregate Information Used for Location Analytics We may aggregate the information we collect from users of our Mobile Products and Third Party Data for reporting and analytics purposes. This is the same data we use to serve and target advertising, and follows the same restrictions and guidelines. Location Analytics refers to the process of aggregating, packaging, and visualizing this data for particular physical locations.

  • Opt-Out of Information Collection You can stop all collection of information by the Mobile Product easily by uninstalling the Mobile Product or by emailing optout@mira.co. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

Third Party Data

Mira obtains data from Third Party Sources, such as other Mobile SDKs and Mobile Advertising Exchanges. These sources each have their own Privacy Policy which applies to the use of the data the sources collect. Mira does not assume any responsibility for any negligence, misrepresentations, or other offenses committed towards the consumer by the Third Party Sources.

  • Personally-Identifiable Information We do not collect Personal Information through our Third Party Sources.

  • Mobile Advertising Identifiers See above (Mobile Products, Mobile Advertising Identifiers) for definition. Mira collects these identifiers from Third Party Sources, if you have allowed the Third Party Sources to access these identifiers. These identifiers are considered not to be personally-identifiable, because they can be reset and are randomly generated.

  • Location Data Mira receives location data from Third Party Sources that was collected according to the Third Party Terms of Service.

  • Opt-Out of Information Collection To remove yourself from our system, email us at optout@mira.co. This, however, will not affect whether Third Party Sources continue to collect information from you. To fully opt out of information collection by Third Party Sources, please consult the Privacy Policies and/or Terms of Service set forth by the Third Party Sources themselves. Feel free to email us at info@mira.co for a list of our sources and guidance.

Disclosure and Sharing of Information

Information about our customers is an important part of our business. We do not rent, sell, or share your Personal Information, Non Personal Information, Mobile Advertising Identifiers, or Location Data (together, your Data) other than as described in the Privacy Policy, including as follows:

  • We may disclose your Data to our service providers who work on behalf of Mira, including to provide our Website or the Mobile Product or fulfill user requests. However, these companies are not allowed to share this information or to use it for their own purposes.

  • We may disclose your Mobile Advertising Identifiers to Third Party Data Providers for the purposes of acquiring additional consumer data. The Mobile Advertising Identifier acts as an index that can be used across datasets, similar to how cookies are utilized. These Third Parties have their own privacy policies that govern the use of the data they collect, which we do not control.

  • We may disclose your Location Data to third parties for the purposes of providing targeted advertisements and information our advertising partners believe may be of relevance and interest to you; these third parties include but are not limited to ad networks and ad serving companies. Advertising helps us provide the Mobile Product and helps our Publishers provide free services and content. You can opt-out of our collection of such Location Data by turning off the GPS capability of your mobile device and rejecting our request to collect such data upon installation of the Mobile Product.

  • We may sell your Location Data to third parties, such as data marketplaces, at the request of the Publisher, in order to supplement the Publisher’s revenues.

  • We may disclose your Data to third parties to provide you with targeted information as requested by you. For example, we will provide your Location Data to a third party partner so that they can provide you with location specific advertising.

  • We may disclose your Non Personal Information, including your IP address and as part of an aggregate data set to third parties for the purposes of providing targeted advertisements and information our advertising partners believe may be of relevance and interest to you.

  • We may disclose your Data to comply with legal requirements or to respond to a subpoena, search warrant or other legal process or government request received by Mira, whether or not a response is required by applicable law.

  • We may disclose your Data to enforce our rights in our Website and Mobile Products or to protect the rights, property or safety of members of the Mira community, our Publishers, other visitors to our Mobile Products, the public, or Mira and its employees.

  • As our business grows, we may buy or sell various assets. In the event that Mira or some or all of our assets are acquired by another company, our users’ Data may be among the transferred assets.

  • In the event that Mira goes through a bankruptcy, reorganization, receivership or similar event, you understand and agree that we may not be able to control how your Data collected by us is treated, transferred or used.

  • Please keep in mind that whenever you voluntarily make your Personal Information available for viewing by third parties on any part of our Website or an Mobile Product, that information can be seen, collected and used by anyone who visits the site. We cannot control and therefore cannot be responsible for any unauthorized third-party use of such information. An example of this is commenting on public pages, posts, and articles. Please respect the privacy of others by not posting their personal information on our site without their permission.

Other Information

Data Retention
If you provide Personal Information to us through our Website, such as signing-up for our newsletter, you may request that we delete such Personal Information from our system, by sending a request to optout@mira.co, or by choosing the limit ad tracking setting on your device’s privacy settings page. We will promptly cease use of any such Personal Information and will remove such Personal Information from our servers in accordance with our standard practices. Certain other components of your Data relating to your use of the Website or Mobile Products, such as Mobile Advertising Identifiers, may be retained indefinitely, but we do not use or share such information once you have uninstalled the Mobile Product.

Social Media Sites, Links To Other Sites
We may have pages, accounts or presence on various social networking and media sites or services, such as Facebook and Twitter. Any information you post or provide through such social media sites and services will be subject to the policies of the applicable site or service.

The Website and Mobile Products may include advertisements and links to third-parties web sites or service whose privacy policies we do not control. When you access another app or site, use of any information you provide on such site or app, and any information collected by the site operator, is governed by the privacy policy of the operator of the app or site you’re visiting. If you click through to any of the advertisers on a Mobile Product, the advertiser may also track your device. We do not have access to or control any information they may contain.

Tracking
We do not track or collect Personal Information about your online activities once you leave our Website or Mobile Product.

Security
Mira has taken steps to protect the confidentiality of the Data it collects from users of its Website and Mobile Products. Information we gather on Mira is stored within Mira controlled databases (or databases hosted on our behalf) on servers maintained in protected environments, and we limit access to such information to Mira employees who we believe need to see that information to provide you with services or otherwise do their jobs. We employ modern security and encryption standards, within reason. However, no physical or electronic security system is impenetrable, and we cannot guarantee the security of our servers or databases, nor can we guarantee that the information that you supply to us won’t be intercepted during transmission over the Internet.

Changes to Our Privacy Policy
Because the web and Mobile Products are evolving mediums, we may need to change our Privacy Policy at some point in the future, in which case we’ll post the changes to this Privacy Policy on our Website and/or within the applicable Mobile Product and update the Effective Date of the policy to reflect the date of the changes. By continuing to use the Website or Mobile Product after we post any such changes, you accept the Privacy Policy as modified.

Contacting Us with Questions
For more information, or if you have questions about this Privacy Policy, please contact us at info@mira.co.