Please read and understand those terms before you use our services because there is important legal stuff there for you to know.
Because your privacy is important to us, we want to tell you very clearly how our products and services collect radio signals and use location information.
Especially Important Disclosure:
Please focus on the fact that the Proximity Platform works by collecting the “addresses” that smartphones and other wireless devices transmit publicly for the very purpose of being discovered and making electronic connections with other devices – sort of like nametags at a conference. We do not know your phone number or your friends’ phone numbers nearby. GSM has created an evolution of location-based services called proximity services, because you or other applications can set up rules to make things happen depending on whether you are in range, or out of range, of devices that you or someone else has tagged. We may also allow you to enable our use of GPS or cellular tower network information in some instances as well.
It is also important for you to know that we do not and cannot collect any “content” from any of your calls, emails, posts, tweets, etc., or other communications that go over your smartphone, or the websites you visit. We just collect the device addresses, and then it is up to you or your friends to link whatever other information or services that you choose to associate with a tagged device. This association feature can incorporate many types of your favorite social media, including your Twitter user name, Linked-in Profile, Facebook name or location data like a Foursquare venue and more—as long as you had previously chosen to make those profiles or feeds unrestricted and public in your privacy settings.
For our service to work, by the way, you need to enable your phone hardware settings for Bluetooth, WiFi, Near Field Communications (NFC if you have it) and GPS and in some instances you need to have a cellular or WiFi data connection to the Internet.
GSM Media Group, Inc.
10990 Wilshire #140
Los Angeles, CA 90024
telephone: (713) 320 55 88
If we make any important changes to our Policy that could let us use or share personal information that we previously collected from you in new ways that we have not already told you about, we will ask for your specific permission for the new things we would like to do.
Additional Very Important Disclosures
First a brief explanation about how our uncommonly cool proximity-based service works. This is actually pretty interesting so definitely read this part:
The GSM Proximity Platform and applications like ToothTag and its technology license partners work because smartphones and other wireless devices have radio transmitters that let them connect to networks or other devices through the air.
Each of these radios has a number or name that is unique to that piece of equipment; you can think of it as a sort of “radio address” that is broadcast into the air so that other devices can “discover” and connect with them.
GSM technologies let your smartphone discover these radio addresses and “tag” them so you can tell when you and your smartphone get close to an important device. GSM collects and uses these unique equipment identifiers so that users like you know when they are the same physical space with other devices whose radio addresses they have tagged. We call this a “proximity” application because users can get notified when a device they’ve tagged comes into or goes out of range, or make certain things happen automatically when you and your smartphone get close to another device you’ve tagged.
“Proximity” for our purposes means how close are you to the device you’ve tagged:
While smartphones and other gadgets publicly broadcast a number of different unique radio addresses, GSM only collects and uses the publicly discoverable names and numbers for WiFi, Bluetooth, GPS, Near-Field-Communications (NFC) devices and some cellular tower location data depending on the technology or carrier. When you sign up to use our service, ToothTag allows you to discover and tag your devices by their unique WiFi, Bluetooth, GPS or NFC addresses. These are based on people’s devices that broadcast publicly or if they check in on popular social networks which contain location information.
While all this radio address information is public, we protect your privacy and other people’s privacy by conspicuously disclosing the following practices to you, and limiting our collection, use, disclosure and storage of information as described below
GSM’s technologies allow you to “tag” (i.e., discover and capture) MAC addresses (i.e., unique alphanumeric equipment identifiers assigned by the device manufacturer) and device names (that can be assigned by either the manufacturer or the individual user such as “John Smith’s wireless router,” “Jane Doe’s iPhone,” “Motorola Headset 9700,” “BMW Bluetooth System,” etc.) for any WiFi access point or radio, or Bluetooth, NFC transmitter that is within range of your GSM Proximity Platform-enabled smartphone.
Any broadcasting WiFi, Bluetooth, GPS or NFC radio or transmitter that is within range of your smartphone can be tagged using ToothTag.
When you tag a device, you can designate a name for that device and what kind of device it is and who or what goes along with that device. For example, “my Droid,” or “Susie’s phone,” or the nickname of your house or coffee shop.
Linking Tagged Devices to Other Services, Like “Foursquare”
You can choose to link tagged devices to public information on third-party services like “Foursquare.” This can be useful, fun and social, but remember that you are responsible for any information disclosed by using these other services, and any information on those third-party services or websites is, of course, governed by their privacy policies.
We use open standards like oAuth to enable other service offerings, which is a common practice for software like ours to enable enhanced features or offerings.
Letting Restaurants and Other Businesses Know You Might Be Interested in Their Offers
As more and more restaurants, cafes, bars, stores and other businesses subscribe to our Proximity Platform (as retail partners), you will be able to let their WiFi or other radio networks send you special offers and other messages when you are within their range.
While you remain a user of GSM or our subsequent products or partner services, you may set up “rules” or automated actions that take place when one or more devices come in or out of range to your smartphone or in or out of range of another subscriber of our services. For example, you could set up a rule that your smartphone buzzes you when your friend’s tagged device is within range of your phone; or you could set up a rule to have your computer start up your favorite playlist when your smartphone is within range of your tagged home WiFi network.
Analyzing and Sharing Location, Movement and Device Data, Including Legal Requests
GSM servers will have considerable information about when and where our user’s devices tag other devices, how long devices stay within proximity, and similar information about locations, movements and number of devices.
Security on your Smartphone
Your tags will be stored on your smartphone or backed up on a cloud database in a file that can only be accessed by the ToothTag application, or an application which you have installed that licenses the technology.
The stored “tag” information will include all the information you have designated for the tagged device, including any personal information you have associated with the tag (such as “Susie’s phone” or “John Smith’s iPhone”), as well as the radio address for that device (such as the MAC address, SSID name or the default device name assigned by the manufacturer).
Security on our Servers
Your tags and rules may also be stored on a secure GSM or partner web page that you will only be able to access with your unique user name and password.
We will store all this information on servers with appropriate commercial security technology and practices, but as you know, there are no guarantees of perfect security due to unforeseen circumstances, weak passwords on a user account, brute force attacks or other cyber-attacks.
Checking, Changing or Deleting Your Information
Your tags (including all of the information described above) will also be stored on our servers for as long as you remain a user of ToothTag or an application that licenses our proximity services, and you will always have access to check, edit, correct or remove information that we have stored about you or your devices.
If you terminate your subscription to GSM, we will delete all of your personal information, including your tags, within 45 days of your termination, except if (and only so long as) we need to retain that information to comply with a government request that we believe in good faith is lawful, or to comply with subpoenas or other legal process, or if necessary to protect our legal rights or property.
Additional Privacy Disclosures
If we use information that we have already collected from you in a manner different than the purpose we originally explained to you, then we will ask for your consent before we use it in the new way.
You can use your GSM account web page to review and control the information stored in your account.
Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some of our features and services may not function properly if your cookies are disabled.
You can also disable Proximity Platform services, including location-based services, at any time by doing any of the following: (1) disabling the “location” feature of your smartphone, (2) removing the ToothTag or the partner application itself, or (3) turning off your WiFi, Bluetooth, GPS and NFC radios and transmitters.
We only share personal information with other companies or individuals outside of GSM or ToothTag if:
We have implemented appropriate security measures, including administrative, technical and physical safeguards, to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. No security measures are foolproof, however, and should we experience a breach of security that could compromise your personal information, we will notify you in accordance with applicable law.
It is our policy to provide notifications, whether such notifications are required by law or are for marketing or other business related purposes, to you via email notice, written or hard copy notice, or through conspicuous posting of such notice on our website, as we determine in our sole discretion, to the extent permitted by law.
Accessing and Updating Personal Information
You may access your personal information on your GSM web page, where you have various options for checking, correcting, editing or deleting data.
Protecting the privacy of young children is especially important. For that reason, we do not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to sign up as GSM Proximity Platform users.
If you are under 13, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 13 is allowed to provide any personal information to or on GSM. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org.
If we receive formal written complaint, we will try to contact the complaining user regarding his or her concerns. We will cooperate with the user and any appropriate regulatory authorities to try to resolve any complaints or concerns in a reasonable and satisfactory manner. You can send it to our mailing address or email@example.com.
GSM Media Group.