Emodo ® Internet Privacy Policy

We understand that privacy is an important issue for users of, and visitors to, the Emodo site www.emodinc.com and its related domains. The following information is designed to help visitors understand what information we collect, and how we handle and use the information after that.

This privacy policy explains the privacy policies Emodo® uses for processing personal information obtained on this website. It applies whenever you use the website or applicable mobile application requesting information or fulfilling service commitments.

Emodo as the Data Controller

When collecting information from our own site, www.emodoinc.com, we act as the Data Controller. As such, we will protect and preserve data in conjunction with GDPR and other regional privacy laws and regulations.

Emodo as the Data Processor

In most of the data that we collect and process, Emodo acts as the Data Processor. In the infrastructure supports we provide to the advertising industry, we process and transfer Personal Data only under the direction of the Data Controller. If inquiring about this data, we can direct you to the appropriate Data Controller to fulfil your request to access, delete, or change your Personal Data.

The following Personal Data types are what Emodo processes on behalf of our Data Controller clients:

  • Customer data This data type typically includes attributes such as subscriber wireless plan name, plan type and zip code. This data is pseudonymized by Advertising ID.
  • Location data Location data defines the geographic location of a device at a point in time. There are multiple data sources to activate location data for monetization such as GPS signal enabled by Apps, Wi-Fi networks and Cellular networks. This data type typically includes attributes such as latitude, longitude, horizontal accuracy and timestamp. This data is indexed by Advertising ID.
  • Session Activity Data Session activity data is derived from anonymizing and aggregating browsing activity data of the user. This type of data allows Emodo to create Segments based on online interests. This data type typically includes attributes such as URL, timestamp, and user agent. This data is pseudonymized by Advertising ID.

When Emodo Transfers Data

Emodo may transfer the information collected to any relevant unit within our parent company, Ericsson Group, which includes the Emodo global locations. The data is transferred under both data transfer agreements and binding corporate rules (BCR) which secure an adequate data protection level in accordance with GDPR and other relevant privacy laws. A summary of BCR can be obtained from https://www.ericsson.com/en/legal/processor-binding-corporate-rules. Our processor binding corporate rules (“BCR”) set down effective and uniform standards for the processing of personal data right across Emodo’s global operations. Our BCR help us to comply with data protection standards within the European Union (“EU”) and the European Economic Area (“EEA”).

In addition to the BCR, Emodo also complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries transferred to the United States pursuant to Privacy Shield.  Emodo has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

Note: Emodo, Inc does not transfer data to agents or unaffiliated third parties. If this practice should change in the future, we will update this policy and provide individuals with opt-out or opt-in choice, as the circumstances require. We may transfer data to contracted Sub Processors that assist Emodo, Inc in platform services, email marketing, cloud-based applications, accounting and other infrastructure support to enable Emodo to conduct business.

Pursuant to the Privacy Shield Framework we acknowledge that we are liable for the onward transfer of personal data to agent third parties unless we can prove that we were not a party to the actions resulting in the damages.

When Emodo Collects Data as a Data Controller with emodoinc.com

General Inquiries

If a user contacts Emodo with a commercial inquiry via our website, the user may need to provide Emodo with personal information (for example contact details). Emodo will use this personal information to respond to the inquiry and track further correspondence. Information can also be used for marketing purposes and to compile statistics on response handling, etc. If you wish to delete any Personal Data you provided from our systems, please email that request to privacy@emodoinc.com.

Extranets

Extranets provide customer-specific content and functions. For this site to properly fulfill its obligation to Emodo’s major customers, we must mutually agree on which personnel may access specific extranet content and use specific extranet functions. Emodo uses cookies, together with additional security mechanisms, to identify and track the registered users who enter extranet or other restricted-access portions of our site.

Marketing

When users come to our website and request further information on the Contact Form, Emodo may use information collected from users, for sales and marketing purposes, including email marketing. This includes email addresses, names, and company information. We may combine this information with data obtained from other sources to help us improve its overall accuracy and completeness, and to help us better tailor our interactions with users. A privacy disclosure of how data will be used and how to unsubscribe from our emails will be on the Contact Form.

As a company with global activities, customers and partners we may need to transfer personal data to any country in the world. Users may choose not to receive marketing materials by following the unsubscribe instructions included in each e-mail or email us at privacy@emodoinc.com.  Please note that the above does not affect users’ ability to reject cookies as stated our Cookie Policy.

External links

This site may contain links to other sites. Please take note that Emodo is not responsible for the privacy policies or practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy policies or privacy statements of each and every site that collects personally identifiable information. This privacy policy applies solely to information collected by this site.

For EU Individuals: Your Rights under the General Data Protection Regulation (GDPR)

EU data subjects have the right to lodge privacy complaints or enforce GDPR rights. This includes both Emodo, Inc. and with a supervisory authority.

Emodo can be contacted for any privacy relates concern, inquiry, or compliant at privacy@emodoinc.com.

Or 

A list of rights and supervisory authorities can be found at http://ec.europa.eu/justice/article-29/structure/dataprotection-authorities/index_en.htm.

Changes to the Internet privacy policy

Emodo may, from time to time, make changes to this policy. We recommend that users of this site re-visit this privacy policy on occasion to learn of new privacy practices or changes to our policy.

How to contact Emodo about this Internet privacy policy

If site users have any questions, concerns, or complaints about this privacy policy, or want to let us know what they think about any of our off-line and on-line products and services, they can use our general contact email address privacy@emodoinc.com.

In compliance with the Privacy Shield Principles, Emodo commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. Pursuant to the Privacy Shield we acknowledge that EU individuals have the right to access their personal data. We allow an individual in accordance with regional laws to access, delete, and change their Personal Data processed by Emodo, Inc. or if we are the Data Processor, we can redirect the individual to the Data Controller that collects their data.

European Union individuals with Privacy Shield inquiries or EU citizens wanting to access, delete, or change their Personal Data housed by Emodo, Inc. should contact us at:

ATTN: Emodo® Privacy Officer
privacy@emodoinc.com

Emodo has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.  See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

The Privacy Shield requires us to inform EU individuals that we may be required to share their personal data in response to lawful requests from public authorities including to meeting national security and law enforcement requirements.

Emodo is subject to the regulatory and enforcement authority of the United States Federal Trade Commission (FTC).

EU data subjects have the right to lodge privacy complaints or enforce GDPR rights. This includes both Emodo, Inc. and with a supervisory authority.

 

Emodo can be contacted for any privacy relates concern, inquiry, or compliant at privacy@emodoinc.com

 

Or

 

A list of rights and supervisory authorities can be found at http://ec.europa.eu/justice/article-29/structure/dataprotection-authorities/index_en.htm.