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. Emodo adheres to the Privacy Shield Principles.
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 or a Service Provider processing data for another company. In the infrastructure supports we provide to the advertising industry, we process and transfer Personal Data, only under the permission and direction of the company that collects the data. If inquiring about this data, we can direct you to the appropriate Data Controller to fulfill 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”).
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
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 email@example.com.
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.
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 firstname.lastname@example.org.
A list of rights and supervisory authorities can be found at http://ec.europa.eu/justice/article-29/structure/dataprotection-authorities/index_en.htm.
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
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).
Our Policy Concerning CCPA
Since January 1, 2020, the California Consumer Privacy Act of 2018 (the “CCPA”) provides California residents with certain rights with respect to their personal information, including the right to opt out of certain disclosures of personal information as explained below.
Ericsson Emodo processes location data and other Personal Information to enable the verification, validation, and delivery of targeted advertising. Ericsson Emodo also collects data from third party data partners such as Cuebiq in the US to enable targeted advertising campaigns for our Advertising and Media clients. Ericsson Emodo does not sell nor transfer your personal Information to any third party.
Under the CCPA, you have the right to have your personal information accessed to determine what Personal Information we may have for you.
You also have the right to delete, correct, and opt out of having us process your personal information at all. We provide this right, subject to a verifiable consumer request. You can do this by emailing email@example.com or calling us at (888) 366-3602 (888-emodo02). You may designate an authorized agent to make a request on your behalf. Please indicate if this request is made on behalf of another.
In addition to providing you the ability to opt out of the “sale” of your personal information under CCPA. Ericsson Emodo does not sell nor transfer your personal Information to any third party.