I. Who is processing the Data?
200 Matheson Blvd. West, Suite no. 200
II. What types of Data do we collect?
The types of Data that the Mapsted Software collects, by itself or through third parties are, or are related to, as the case may be:
✓ Device attributes: information such as device brand, device market name, device model, operating system, operative system version, device manufacturer and product information.
✓ Identifiers: information such as Mapsted internal database-generated device ID.
✓ Device signals: information such as GPS/cellular location, WiFi received signal strength, WiFi connectivity, BLE accelerometer, magnetometer/magnetic field, gyroscope and barometer/atmospheric pressure.
✓ Usage data: information such as, but not limited to, Mapsted Software usage data regarding search history and trajectory. For avoidance of doubt, Mapsted may also collect and process other usage data types, as the case may be.
Data may be freely provided by the User, or collected automatically when using the Mapsted Software.
Unless specified otherwise, all Data requested by the Mapsted Software is mandatory and failure to provide such Data may make it impossible for the Mapsted Software to provide its services.
In cases where the Mapsted Software specifically states that some Data is not mandatory, Users are free not to communicate the respective Data without consequences to the availability or the functioning of the Service.
Users are exclusively responsible for any third party Data obtained, published or shared through the Mapsted Software and confirm that they have the third party's consent to provide the Data to Mapsted.
In addition, Users are exclusively responsible for any Data shared with any third party, if such is technically possible, such as, but not limited to, the case of showing any Data, such as, but not limited to, its route or location, displayed on the screen of the device which has the Mapsted Software installed. For avoidance of doubt, the term "technically possible" excludes any Data gathered by the Mapsted Software in the background.
For operation and maintenance purposes, the Mapsted Software and any third party services may collect files that record interaction with the Mapsted Software, such as system logs and may use other types of data for this purpose, that do not represent "personal data" pursuant to the provisions of the GDPR.
III. We do not collect personal data
The Data does not qualify as "personal data" pursuant to the provisions of the GDPR, since it does not identify, directly or indirectly, a particular natural person.
All of the Data collected through the Mapsted Software is anonymous or anonymized.
IV. For what do we use this information?
For provision of the Services
The Data concerning the User is collected and used to allow Mapsted to provide its Services.
For other Mapsted apps
Also, certain types of Data described above may be collected and used for the services provided by other Mapsted products such as Mapsted Marketing and Mapsted Analytics.
✓ Mapsted Marketing represents the software application owned by Mapsted, whereby certain advertising business clients or otherwise retailers can create ads by using geo-targeted hyper-localized marketing techniques;
✓ Mapsted Analytics represents the software application owned by Mapsted which delivers insights on shopper behaviour and traffic patterns, using sophisticated, multi-layer data mining and predictive analytics in order to help enhancing operational efficiency and facility management while optimizing marketing campaigns to target shoppers more effectively;
Such Data that may be collected for the services provided by Mapsted Marketing and Mapsted Analytics does not qualify as "personal data" pursuant to the provisions of the GDPR, nor does identify, directly or indirectly, individually or taken as a whole, a particular natural person.
Furthermore, such Data that may be collected for the services provided by Mapsted Marketing and Mapsted Analytics does not record any individual/private/personal data, such being in all circumstances collected and processed as referring to a group of natural persons, thus, being anonymous or anonymized in respect of a single natural person, in compliance and pursuant to the provisions of the GDPR and other applicable data privacy regulations.
In case of legal action
The Data may be used for legal purposes by Mapsted in court or in the stages leading to possible legal action arising from improper use of the Mapsted Software or the related Services.
The User declares to be aware that Mapsted may be required to reveal certain Data upon request of public authorities.
V. How do we use this information?
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated herein.
The Data is processed at Mapsted's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the Data to a country other than their own.
The Data is collected and processed during the Calibration Phase and Positioning Phase.
✓ Calibration Phase is the phase describing the Mapsted proprietary process of completely mapping any building by using the Mapsted Software while walking a certain amount of distance for a certain amount of time inside the respective building;
✓ "Positioning Phase" means the phase describing the position of a natural person walking a certain amount of distance for a certain amount of time inside a certain building;
VI. How long do we store this information?
Data shall be processed and stored for as long as required by the purpose such has been collected for.
Data collected for purposes related to the performance of a contract between Mapsted and the User shall be retained until such contract has been fully performed.
Data collected for the purposes of Mapsted's legitimate interests shall be retained as long as needed to fulfill such purposes.
Mapsted may be allowed to retain Data for a longer period in certain circumstances, according to its interests, which shall be decided at its sole discretion. Furthermore, Mapsted may be obliged to retain Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of a public authority.
Once the retention period expires pursuant to the above, the relevant Data shall be deleted.
VII. How is this information shared?
In addition to Mapsted, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the Mapsted Software (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies). The updated list of these parties may be requested from Mapsted at any time.
As mentioned, Mapsted may employ third-party companies and individuals for the following reasons:
✓ to facilitate the Services of the Mapsted Software;
✓ to provide the Services of the Mapsted Software;
✓ to perform services related to the Services of the Mapsted Software; or
✓ to assist Mapsted in analyzing how the Services of the Mapsted Software are used.
VIII. What is our legal basis for processing data?
Mapsted may process Data relating to Users if one of the following alternative premises applies:
✓ Users have given their consent for one or more specific purposes, either (i) implicitly by using the Services of the Mapsted Software, or (ii) expressly, by completing a positive action, such as ticking a box or other similar methods, however the latter only if Mapsted opts for such a method, at its sole discretion;
✓ provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
✓ processing is necessary for compliance with a legal obligation to which Mapsted is subject;
✓ processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in Mapsted; and
✓ processing is necessary for the purposes of the legitimate interests pursued by Mapsted or by a third party.
In any case, Mapsted will reasonably help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
IX. How do we secure the information?
Mapsted takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
In this regard, Mapsted shall use commercially acceptable means of protecting the Data. However, note that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and Mapsted cannot guarantee the absolute security of the Data.
X. What about the Data processed by third party software?
Mapsted is responsible for the Data collected and processed by its Mapsted Software, as long as such is stored by Mapsted Software.
However, Mapsted is not, under any circumstances, responsible, nor liable for any Data exclusively processed and collected by any third party software, when the latter is implementing and incorporates the Mapsted SDK.
XI. How links to other sites are managed?
The Services provided through the Mapsted Software may contain links to other sites.
Mapsted has no control over, and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
XII. How do we contact Mapsted with questions?
More details concerning the collection or processing of Data may be requested from Mapsted at any time. Please see the contact information at the beginning of this document.
XIII. How are the changes to this policy managed?
XIV. What do certain terms in this policy mean?
"Data" means any information collected by the Mapsted Software, for the purpose of providing its Services;
"GDPR" means the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016;
"Mapsted Navigation App" means a software application developed and maintained and owned by Mapsted for the Android and iOS smartphones and found on the following links: (i) https://play.google.com/store/apps/details?id=com.mapsted.navigation&hl=en_CA for the Android platform or (ii) https://itunes.apple.com/ca/app/mapsted-navigation/id1278508782?mt=8, for the iOS platform;
"Mapsted SDK" means the software described on the following link: https://mapsted.com/products/mapsted-sdk.html, which implements the Mapsted Indoor Navigation Technology, available for both Android and iOS smartphones.
"Mapsted Software" means the software owned by Mapsted and used for the processing and collection of the Data, namely:
a) Mapsted Navigation App used either directly or indirectly through Mapsted SDK; and
b) Mapsted SDK, when used and incorporated into a software application owned either by Mapsted or a third party.
"Service" means the service provided by the Mapsted Software; and
"User" means the natural person using the Mapsted Software.