Freckle Privacy Policy

(the “Policy”)


Freckle IoT Ltd. (“we”, “us”, “our” or “Freckle”) gathers location and point of interest data (the “Data”) and shares it with customers and third parties in the manner described herein (“Services”). The Policy describes how Freckle collects and uses the Data from end users and their mobile devices.


How is the Data Collected

Freckle engages with the owners (often referred to as “Publishers”) of mobile applications (“Apps”) whereby the Publishers will incorporate into their Apps Freckle’s beacon technology (often referred to as a software development kit or “SDK”). The SDK will enable Freckle to understand the geolocation of the end user as the SDK communicates with physical and virtual beacons that the end user of the Apps may come into contact with (“Beacon Technology”). Once Freckle obtains this information it will, through its data management platform, make inferences about your interests as more fully described within the Policy.


What is the Data Collected

We will never know who you are. We will make inferences about your interests based on the information we collect. The type of information that we may collect include:

  • Your location (e.g., latitude/longitude coordinates), time of day or your location when/if your device is near any of our beacons – small devices that may use Bluetooth and be placed, for example, in retail stores or other locations;
  • Demographics (such as gender, age range, etc.) and interests (such as sports, music, etc.) that Freckle infers on your device from your location history and the advertising identifiers on the device.
  • Information about your device (e.g., make, model, OS, and other similar information, but not phone number);
  • The state of the end-user device (e.g. location services on/off, Bluetooth on/off, WiFi on/off, cellular data on/off, and other similar information);
  • The information about the app permissions (e.g., deliver notifications, use location services, use Bluetooth, and other similar information);
  • The status of the Freckle SDK (e.g., which Features are activated/deactivated, whether the SDK is activated/deactivated, and other similar information); Information about your version and use of Freckle and Freckle-Powered Apps such as use of features, functions, or clicks on notifications or content;;

We shall not collect and use any of the following or related information:

  • Hardware-based identifiers such as UDID (Unique Device Identifier), Media Access Control (MAC) Address;
  • Personal information, such as name, address, email, or telephone number; and
  • Sensitive information, such as health, political opinions, religion.


Use of the Information Collected and Who We Share it With

The information that we collect will be used for the purposes outlined below and only shared with Publishers, Advertisers, affiliates, and our customers. We will obtain your consent for any additional use unless otherwise required to disclose the information by law.

We collect and share information and data in order to:

  • Notify us and Freckle-Powered Apps when you arrive at or leave locations designated by such Freckle-Powered Apps such as at a retailer’s store or a particular section within a retailer’s store;
  • Notify us when you arrive at or leave locations where Freckle beacons are installed such as at a retailer’s store or a particular section within a retailer’s store;
  • Infer the places you visit most often, determine your frequency at these locations, and notify Freckle-Powered Apps when you arrive at or leave those places;
  • Send you notifications from time-to-time in order to update you about any events, promotions, or relevant content;
  • Create a profile that may contain inferences that we or Freckle-Powered Apps may make about you such as your age range, income range, gender, and interests (e.g., sports, cooking, music, etc.) (the “Freckle Profile”);
  • Share the Freckle Profile with Freckle-Powered Apps to create a more personalized experience or with Advertisers to create interest based advertising;
  • Share the Freckle Profile for advertising uses such as attribution, segmenting, de-duping, and re-targeting;
  • Improve Freckle, its systems and services;
  • Respond to requests that you may send us such as your request for information, your request for customer support, or your request to subscribe to a service we offer;
  • Use comments or feedback you voluntarily provide us about our products and services (including your name if you provide it) in our advertising, marketing, or promotional materials; To the extent permitted by applicable law, combine the various types of data that we collect with data that we obtain from third parties or other sources and use the combined data for any of the purposes described in this Policy;
  • De-identify, aggregate or otherwise make the data we collect anonymous and use that information for our business purposes. This privacy policy does not apply to data once it has been aggregated or de-identified; and
  • Any other use we describe at the point where we collect the data with your consent.


How you may opt-out of our Collecting Information

If you no longer wish to receive notifications from us, have us create a Freckle Profile, or do not wish that we collect information about you to create de-identified and anonymous demographic profiles via mobile applications you use, you may change your mobile device settings to prevent it.

Apple devices

If you have an Apple device, you can opt out of app-based tracking for interest-based advertising by updating to iOS 6.0 or higher, and setting Limit Ad Tracking to ‘ON’. For iOS 6, you can do this by selecting Settings -> General -> About -> Advertising and toggling Limit Ad Tracking to ‘ON’. For iOS 7 and higher, you can do this by selecting Settings -> Privacy -> Advertising and toggling Limit Ad Tracking to ‘ON’. You can obtain further information on how to limit ad tracking on your iOS device or to reset your IDFA here: IDFA Opt-Out.

Android devices

If you have an Android device, you can opt out app-based tracking for interest-based advertising by taking the following steps i) Open the Google Settings app on your device; ii) Select “Ads”; and iii) Opt out of interest-based ads. You can obtain further information about how identifiers on mobile are used for advertising and receive instruction for how to opt out of mobile advertising here: Google Privacy & Terms webpage.


Our Corporate Websites

When you make use of our corporate website we may collect and store information related to your use of the websites, such as your IP Address or Mobile advertising ID, and information pertaining to your mobile device, network, protocols and software and the date and time of your visit. We will use this information to help us provide a more relevant and useful site experience to you. This information is also used in the aggregate to perform statistical analyses of user behavior and characteristics in order to measure interest in and use of the various areas of the websites. In order to use some functions of these websites, you may be required to register or provide personal information, such as your name and email address. This information will be used only for the purposes of providing you with the functionality you have registered for


Retention and Security of Information Collected

We understand how important protecting your privacy is, and we are committed to safeguarding the information you provide to us. And while we cannot guarantee absolute security, we have implemented specific security procedures to protect the storage and disclosure of your information. Access to your information is restricted to select employees or representatives. We will retain your information and the information we process on behalf of our customers for as long as your account is active or as needed to provide you services. By default, Freckle stores information on your device for up to sixty days and on our servers for up to one year (at which point information is overwritten on a rolling basis). We may retain anonymized, non-personal data for an extended period of time, in order to compile and create general profiles of users, demographic information and interests so as to enable Publishers, Advertisers and our customer to understand Platform users. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.


Privacy Officer

We are responsible for and will maintain and protect information in our possession or custody. We have designed an individual or individuals who is/are accountable for compliance with this Privacy Statement.

To contact us concerning privacy issues, please send a letter to:

Attn: Privacy Officer
Freckle IoT
409 King St. W
Suite 400
Toronto, Ontario, M5V 1K1


Changes to This Privacy Statement

We reserve the right to modify this Privacy Policy from time to time. We will notify our members of relevant changes by posting a notice on our website. The most current version of this Privacy Policy will govern our use of your information, and will always be located here.