Mira Privacy Policy

Last Updated and Effective as of: February 10, 2021

We at The Spoken Thought, Inc. (“Company”, “Mira” “we”, “our” or “us”) understand that privacy is important to you. This Privacy Policy below discloses our practices regarding information collection and usage for mira.co (the “Website”), and through mobile applications using the Mira SDK (the “Mobile Product”, and collectively with the Website, the “Services”). Additionally, Mira collects certain information indirectly through third 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. Our use of data from the Mobile Products will be governed by this Privacy Policy, but our content partners (“Publishers”) may have their own applicable privacy policy. This Privacy Policy does not apply to any other websites, apps or services provided by us or our affiliates, unless it appears on such website, app or service.

Overview

  • We collect information from users of our Website when it is voluntarily provided by the user (see Information Collection and Use).
  • We automatically collect information from users of our Services for advertising and analytical purposes (see Information Collection and Use).
  • You can access, delete and control certain uses of your information (see Rights, Choices, and Opt Out).
  • We will not use or share your information except as described in this Privacy Policy.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, you should not use the Website or install the mobile applications that use the Mobile Product. By accessing or using our Services, you agree to this Privacy Policy. If you have questions, you can always contact us using the information in the section below titled “Contacting Us With Questions”.

If you are a resident of California, please see the section titled “Information, Notices, and Rights Applicable To California Residents Only” for specific disclosures with respect to our collection, use, and disclosure of your information and additional rights you have under applicable law.

Information Collection and Use

Information Collected on Our Website

1. Information You Provide

You are not required to register or provide any Personally Identifiable Information in order to browse our Website and learn more about our company, our products, and our technology. We do not collect Personally Identifiable Information unless you submit that information to us through the Website, such as when you choose to subscribe to our newsletter or otherwise provide information directly to us or interact with us on the Website. “Personally Identifiable Information” is information that specifically identifies you. For example, the categories of Personally Identifiable Information we collect may include your name and contact data (e.g., address, email address, telephone numbers).

2. Cookies and Other Tracking Technologies on Our Website

We or our third party partners may store some information on your device or device hard drive as a “cookie” or similar type of file (such as clear gifs, web beacons, tags, and similar technologies that work on mobile devices) to collect data related to usage of the Website and for the purpose of facilitating and enhancing your communication and interaction with the Website. Such data may include, without limitation, the address of the websites you visited before and after you visited the Website, the type of browser you are using, your Internet Protocol (IP) address, what pages in the Website you visit and what links you clicked on, and geolocation data. We use this information to help us maintain and enhance the efficiency and usefulness of the Website and may use it and other non-Personally Identifiable Information for the purposes described in this Privacy Policy, such as to serve targeted advertising to you. However, some of the information we collect may include data, such as IP address data or the identifiers associated with your device that are unique to your computer or device (e.g., IDFA for iOS and Android ID for Android).

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. For more information, learn how Google uses data when you visit their partners’ sites or apps. You can opt out of Google Analytics on most browsers through the mechanisms made available by Google here.

Cookies and similar items are not used by us to automatically retrieve information that can identify you from your device without your knowledge. Please be advised that certain third parties that are beyond the scope of this Privacy Policy may collect information in connection with the Website. We are not responsible for the acts or omissions of such third parties.

If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website or some of its functionality may be affected.

3. Clickstream Data

As you use the Internet, a trail of electronic information is left at each website you visit. This information, which is sometimes referred to as “clickstream data” can be collected and stored by a website’s server. Clickstream data can tell us the type of device and browsing software you use and the address of the website from which you linked to the Website. We may collect and use clickstream data to anonymously determine how much time visitors spend on websites, how visitors navigate throughout websites and how we may tailor our Website to better meet consumer needs. This information will be used to improve our Website. Any collection or use of clickstream data will not intentionally contain any information that specifically identifies you.

Information Collected on our Mobile Products

1. Scope

Mira’s Mobile Products (e.g., for example, the SDKs for each of the mobile applications) collect data about mobile devices. We do not collect Personally Identifiable Information through our Mobile Products, although certain information may be unique to your computer or device. These Mobile Products are often used via a Publisher’s own mobile properties, which act as a host for the Mobile Products. Mobile Products may be used “indirectly” via use of a Publisher’s own mobile product. This Privacy Policy does not govern the use by a Publisher of any information you may provide to the Publisher through our Mobile Product, the Publisher’s mobile product, or otherwise. Before sharing any information with any Publisher, you should review the privacy policy of the Publisher.

2. Automatically Collected 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.

3. 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 Advertisers (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 randomly generated and do not specifically identify you, however, they are specific to your computer or device. You can reset these identifiers through the settings on your device.

4. 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 above. It is important to note that Location Data is not mappable to any Personally Identifiable Information in the manner that we collect it.

5. Aggregate Information Used to Serve and Target Ads

We may aggregate the information we collect or receive about you with information relating to others to help and serve target ads. For example, we may aggregate precise Location Data we collect about you with precise Location Data about others and use this aggregated data 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 Party Sources; this is described in the next section. When we aggregate your information, no Personally Identifiable Information is included.

6. 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.

Third Party Data

1. Scope

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

2. Mobile Advertising Identifiers

Mira collects these identifiers from Third Party Sources, if you have allowed the Third Party Sources to access these identifiers.

3. Location Data

Mira receives Location Data from Third Party Sources collected according to the Third Party Source’s terms of service and privacy policy.

Use and Disclosures.

In addition to the above, we may use and disclose your information, including your Personally Identifiable Information as follows:

  • to contact you about our products and services and provide you with our products and services;
  • to personalize your experience with us including by presenting products or offers tailored to you;
  • to allow you to use and interact with our Services;
  • to respond to your direct inquiries;
  • to add you to our mailing lists and send you emails from time to time;
  • by our service providers who work on behalf of Mira, including to provide our Website or the Mobile Product or fulfill user requests;
  • to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
  • to carry out our obligations and enforce our rights, including in connection with our Services and any contracts entered into between you and us;
  • to protect the rights, property, or safety of members of the Mira community, our Publishers, other visitors to our Services, the public, or Mira and its employees;
  • as described to you when collecting your Personally Identifiable Information; and
  • to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personally Identifiable Information held by us about our users is among the assets transferred.

We may also disclose your Mobile Advertising Identifiers to Third Party Sources 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 Party Sources have their own privacy policies that govern the use of the data they collect, which we do not control.

We may disclose information that is not Personally Identifiable Information, including your IP address and Mobile Advertising Identifiers, including 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.

Please note that if you specifically consent to additional uses of your Personally Identifiable Information, we may use your Personally Identifiable Information in a manner consistent with that consent. Finally, we reserve the right to use and disclose information that is not Personally Identifiable Information in any manner permitted by law except as otherwise provided in this privacy policy.

Interest Based Advertising

We believe that advertising is more effective and relevant when it is targeted to your interests and behaviors. Therefore, we may work with third parties who collect information on our Website and elsewhere through the use of cookies and similar methods in order to serve you with relevant advertisements on other services or to determine that you have seen our advertisements on other services. For example, if you view information on our or a third party website regarding a particular product and service, advertising on other websites and services (such as unaffiliated websites and social media services) about the same or related products and services may be targeted to you. This method of advertising is sometimes called “interest-based advertising.”

Please see the “Rights, Choices and Opt Out” section below to see how you can control certain advertising practices.

We do not respond to or honor “do not track” (a/k/a DNT) signals or similar mechanisms transmitted by web browsers.

Rights, Choices, and Opt Out

Mobile Product and Third Party Sources

To stop all collection of information by the Mobile Product, you can uninstall the Mobile Product or email privacy@mira.co. You can also remove yourself from our system by emailing us at privacy@mira.co. This, however, will not affect whether Third Party Sources continue to collect information from you. To see what opt-out rights you may have with respect to the information collection by Third Party Sources, please consult the privacy policies set forth by the Third Party Sources themselves.

Interest Based Advertising

You do have the ability to control certain advertising practices. You can opt-out of targeted advertising from certain providers at www.aboutads.info/consumers. Please note that by opting out, you will continue to see generic advertising that is not tailored to your specific interests and activities. The opt-out process through the Digital Advertising Alliance (DAA) relies upon the placement of an opt-out cookie on your device. To be clear, cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted out on the browser of your computer, that opt-out will not be effective on your mobile device. You must separately opt out on each device and each browser. If you delete your cookies, you will need to opt out again. For targeted advertisements delivered through mobile apps, you can install the DAA’s AppChoices app on your device to opt-out of targeted advertising by certain providers and can also select a system level advertising preference feature on your device (such as “Limit Ad Tracking” on Apple devices or “Opt-out of Interest-based ads” on Android devices).

Location Data

You can opt-out of our collection of 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.

Cookies

If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website or some of its functionality may be affected.

Deletion Request

If you provide Personally Identifiable Information to us through our Website, such as signing-up for our newsletter, you may request that we delete such Personally Identifiable Information from our system, by sending a request to privacy@mira.co, or by choosing the limit ad tracking setting on your device’s privacy settings page. Except as otherwise permitted by applicable law, we will promptly cease use of any such Personally Identifiable Information and will remove such Personally Identifiable Information from our servers in accordance with our standard practices or as required by law.

Information, Notices, and Rights Applicable to California Residents Only

California law provides California residents with specific rights regarding their personal information. This section describes the rights that California residents have and explains how to exercise those rights, subject in all cases to any limitations set forth in the CCPA (as defined below).

Information We Collect

We collect information (some of which may also constitute Personally Identifiable Information) that identifies, relates to, describes, references, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. The California Consumer Privacy Act of 2018 (“CCPA”) refers to such information as “personal information”. The Services have collected the following categories of personal information from California residents within the last twelve (12) months: personal identifiers (i.e., advertising identifiers), personal information covered by the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), internet or other similar network activity, Location Data, and inferences drawn from other personal information. Please refer to the section entitled “Information Collection and Use” above for more detail about the purposes for which and sources from where we collect personal information, and the third parties with whom we share personal information.

Sharing of Personal Information

Mira may disclose your personal information to a third party for a business purpose or sell personal information collected through Third Party Sources, subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights). We may share your personal information with certain third parties as described above under “Information Collection and Use”

Disclosures of Personal Information for a Business or Commercial Purpose

In the preceding twelve (12) months, Company has disclosed personal identifiers (i.e., advertising identifiers), internet or other similar network activity, Location data, and inferences drawn from other personal information for a business or commercial purpose.

Sales of Personal Information

In the preceding twelve (12) months, Company has sold personal identifiers (i.e., advertising identifiers), internet or other similar network activity, and inferences drawn from other personal information.

California Specific Rights, Choices and Opt-Outs

The CCPA provides California residents with specific rights regarding their personal information. This section describes the rights that you have under CCPA if you are a California resident and explains how you can exercise those rights.

1. Right to Know About Personal Information Collected, Disclosed or Sold. You have the right to request that Mira disclose certain information to you about our collection, use, disclosure or sale of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, and Deletion Rights), and subject to certain limitations that we describe below, we will disclose such information to you. You have the right to request any or all of the following:

  • The categories of personal information we collected about you.
  • The categories of sources from which the personal information is collected.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you
  • The categories of personal information about you that we have sold or disclosed for a business purpose

2. Right to Request Deletion. You have the right to request that Mira delete any of your personal information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records. However, we may retain personal information that has been de-identified or aggregated.

Furthermore, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) in order to perform certain actions set forth under CCPA, such as detecting security incidents and protecting as illegal activity.

3. Exercising Access and Deletion Right. To exercise the access and deletion rights described above, please submit a request to us by either:

Only you, or a person or business entity registered with the California Secretary of State that you authorize to act on your behalf (an “authorized agent”), may make the requests set forth above. If you use an authorized agent to make a request, you must provide the authorized agent written permission to do so, and we may require that you verify your identity directly with us. You may also make a request on behalf of your minor child.

The request should include your contact information and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. In addition, you should provide sufficient information (including your advertising identifier) that allows us to reasonably verify that you are the person about whom we collected the personal information or an authorized representative.

For more information about verification, see Response Timing and Format. For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.

4. Response Timing and Format. We will respond to consumer requests in a reasonably timely manner. If we require extra time to respond, we will inform you of the reason and extension period in writing.

In order to protect the security of your personal information, we will not honor a request if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. The method used to verify your identity will vary depending on the nature of the request. Generally speaking, verification will be performed by matching the identifying information provided by you to the personal information that we already have.

We will deliver our written response electronically or, at your option, by mail. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. We are not obligated to provide the information set forth above under Right to Know About Personal Information Collected, Disclosed or Sold more than twice in a 12-month period.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

5. Personal Information Sales Opt-Out and Opt-In Rights

You have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 and less than 16 years of age, or the parent or guardian of a consumer less than 13 years of age.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us through the following link:

Do Not Sell My Info

Alternatively, you may submit an opt-out request by emailing us at privacy@mira.co. If you use an authorized agent to exercise the right to opt-out, you must provide the authorized agent written permission to do so, and we may deny the request if the authorized agent does not submit proof that it has been authorized by you to act on your behalf. You may change your mind and opt back in to personal information sales at any time by emailing us at privacy@mira.co.

6. Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights, including, but not limited to, by:

  • Denying you goods or services.
  • Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Providing you a different level or quality of goods or services.
  • Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Privacy of Children

Protecting the privacy of children is especially important. For that reason, Mira does not knowingly collect Personally Identifiable Information from children under 13 (or under 16 in the case of California residents) through our Services. If you are under 13 (or under 16 in the case of California residents) do not use or provide any individually identifiable information on this Website. If Mira learns that we have collected or received Personally Identifiable Information from a child under 13 (or under 16 in the case of California residents) through the Services, then Mira will take the appropriate steps to delete that information, or otherwise obtain any consents required by law. If you believe we might have any Personally Identifiable Information from or about a child under 13 (or under 16 in the case of California residents), and would like to have such information deleted, please contact us at privacy@mira.co.

Data Retention

We will retain your information for as long as your account or inquiry is active or as needed to provide you with the Website or our Service to our customers and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your Personally Identifiable Information, we may continue to retain and use aggregate or anonymous data previously collected and/or anonymize or aggregate your Personally Identifiable Information.

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-party web sites or services 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.

You should be aware that Personally Identifiable Information which you voluntarily include and transmit online in a publicly accessible blog, social network or otherwise online may be viewed and used by others. We are unable to control such uses of your Personally Identifiable Information, and by using such services you assume the risk that the Personally Identifiable Information provided by you may be viewed and used by third parties.

Tracking

We do not track or collect Personally Identifiable Information 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 our Services 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 privacy@mira.co.