Complementics GDPR Policy

Last updated: June 15, 2022

This GDPR Privacy Notice (“Notice”) provides individuals in the EEA/UK or Switzerland additional information and choices as to how Complementics process your Personal Information. Please also read our Privacy Policy here.

If you have any questions about Complementics’ data practices in the context of the GDPR, you may contact our Data Protection Officer at [email protected]. You may also contact us at 1074 W Taylor St #371 Chicago, IL 60607.

We provide this Notice as a controller of your Personal Information.

We are the organizers of the Complementics Network, comprised of entities that are our customers. As part of the Complementics Network, we may collect or receive your precise location, information about your usage of the app, and your device’s Advertising ID. This information is collected through our clients’ mobile apps and services that have incorporated our technology (tags and software development kit, known as “SDK”), so that we can provide mobile ad measurement, analytics and other ad services to customers.

Some of our customers participating in the Complementics Network are based in the EEA or UK. If you download or use a mobile app of one of our customers based in the EEA or UK, we collect Personal Information about your precise location, your usage of the app and your device’s Advertising ID only if you have first provided your informed consent to our customer.

If you are using a mobile app published by Unacast, you may also contact them about the collection of your Personal Information on the Unacast mobile app at [email protected] or review their Privacy Policy at Privacy — Unacast.

If you are using a mobile app published by Zeotap, you may also contact them about the collectiono of your Personal Information on the Zeotap mobile app at [email protected] or review their Privacy Policy at Privacy — Zeotap.

For more information, please continue reading.

When you download or use any mobile app of one of our customers that is part of the Complementics Network and not based in the EEA or UK, we will automatically collect Personal Information about your precise location, your usage of the app and your device’s Advertising ID, in order to share it with other customers of ours.

Purpose and legal basis for processing your Personal Information

The GDPR requires us to tell you about the legal basis we’re relying on to process any Personal Information about you. There are different legal bases:

You provided your consent. To obtain this consent, we rely on our own compliance steps and those of our Complementics Network customers based in the EEA or UK, designed to ensure that consent is collected and passed on to us, and to ensure that we only facilitate the collection of legally obtained data. We may choose to obtain consent in other cases as well, in which event we will adhere to applicable laws relating to such consent and its withdrawal. We also seek to obtain consent for certain customers with whom we work, who are often independent data controllers. We list these customers in our List of Customers, below.
The processing is in our legitimate interest. In some cases, we use legitimate interest as a legal basis for processing Personal Data, where our legitimate interests are not overridden by your interests or fundamental rights and freedoms.
Contractual performance and pre-contractual steps. Sometimes, we process certain data as necessary to perform a contract with you, or take pre-contractual steps at your request.

The purposes and legal bases for our processing your Personal Information are described below:

Provide our services to our customers by collecting precise location and app usage information of persons who use mobile apps of our customers participating in the Complementics Network. In collecting this information, we gain access to your Advertising ID stored on your device, and store and share that information with other customers (legal basis: your consent, when you use an app of a customer based in the EEA or UK; otherwise, we rely on our legitimate interests in developing and growing our business)

Operate the Complementics Network and our services and websites and provide related support, including to communicate with you about your use of our websites and services (legal basis: our legitimate interests in promoting our business and services in order to grow our revenues)

Fulfill your orders and requests, process your payments, communicate with you, provide troubleshooting and technical support and similar service and support purposes; provide you with information and services you request, including to respond to your inquiries (legal basis: contract performance or pre-contractual steps at your request)

Customize content, advertising, and your experience when using mobile apps of our customers participating in the Complementics Network, or using our services and websites, including to tailor content we may send or display to you such as to offer location customization and personalized help and instructions, and to otherwise personalize your experiences (legal basis: our legitimate interests in personalizing and improving our services in order to grow our revenues)

Communicate with you about service updates and other administrative issues (legal basis: contract performance)

Measure and improve our sites and services and conduct bug-prevention in our services (legal basis: our legitimate interests in improving our services in order to grow our revenues)

Analyze site and user behavior and prepare aggregated reports (legal basis: our legitimate interests in improving our services and site interactions in order to grow our revenues)

Tell you about our services and those of our corporate family products and services on third-party websites, as well as for direct marketing and advertising purposes, including to send you newsletters, alerts and information we think may interest you; if you are located in a jurisdiction that requires opt-in consent to receive electronic marketing messages, we will only send you such messages if you opt-in to receive them; (legal basis: our legitimate interests in promoting our business and services in order to grow our revenues, or your consent where required)

Protect our legal rights and preventing misuse, such as to protect our websites, business operations; enforce agreements and resolve disputes; prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party (legal basis: our legitimate interests in conducting our business in compliance with laws in order to protect our reputation)

Comply with our legal obligations, for example to comply with the law or legal proceedings, including to disclose information in response to subpoenas, court order, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements, or respond to requests in connection with litigation or dispute resolution (legal basis: our legitimate interests in conducting our business in compliance with laws in order to protect our reputation)

Administration of our general business, accounting, recordkeeping and legal functions (legal basis: our legitimate interests in conducting our business in compliance with laws in order to protect our reputation)

General business operations, for example to implement financings, mergers, acquisitions, reorganizations, and other business transactions (including any related negotiations) (legal basis: our legitimate interests in efficiently organizing our business in order to grow our revenues)

List of Customers

Customers who participate in the Complementics Network and wish to have us publish their name and contact details are listed below:

Unacast.com – Unacast may be reached at [email protected]

Near.com – Near may be reached at [email protected], or by mail at

Near Intelligence Holdings Inc.
100 W Walnut St, 4th Floor
Pasadena, CA 91124

https://near.com/privacy

Transfers of Personal Information

Complementics is located in the United States (US) and your Personal Information will be transferred to the US; the European Commission has not determined that US laws provide adequate protection to Personal Information. When we transfer Personal Information outside of the EEA, UK or Switzerland, we take steps to make sure that appropriate safeguards are in place to protect your Personal Data. In general, our data transfers of our Personal Data are safeguarded by European Standard Contractual Clauses where this is required by European data protection law. Feel free to contact us at [email protected] for more information about the safeguards we have put in place to protect your Personal Information.

Retention of Personal Information

As a general matter, we retain your Personal Information for as long as necessary to provide our services to our customers, or to website users of our services, or for other important purposes such as complying with legal obligations (auditing, corporate record-keeping), resolving disputes, enforcing our agreements (compliance accounting) or bug-prevention.

As described above, under certain conditions we collect Advertising IDs. These are unique identifiers for mobile devices that are collected from persons who consent to our collection of their Personal Information when they use a mobile app published by one of our customers participating in the Complementics Network. We retain Advertising IDs on the following schedule: we render Advertising IDs inactive for purposes of providing our services to our customers participating in the Complementics Network within 13 months from receipt of consent (or from any “refreshed” consent permitting us to continue to retain information), provided that we may retain data for longer periods, as needed, where we have fully de-identified such data in a manner so that it cannot be linked to Personal Information.

Your Rights as a Data Subject

You have certain rights in respect of Personal Information that we hold about you, including certain rights to access Personal Information, to request correction of the Personal Information, to request to restrict or delete Personal Information, and to object to our processing of your Personal Information, as described below.

Right to Access: You have the right to obtain information about the Personal Information about you that we process, and to obtain a copy of your Personal Information. In some cases, you can directly access your Personal Information yourself. In this case, we will provide you with current, step-by-step instructions to follow in order to obtain access.
Right to Correct: You have the right to correct your Personal Information that is not accurate or out of date.
Right to Object to Processing (including profiling) based on Legitimate Interests: Where we are relying upon legitimate interests to process Personal Information, you have the right to object to that processing based on grounds relating to your particular situation. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or we need to process the Personal Information for the establishment, exercise or defence of legal claims. Where we rely upon legitimate interest as a basis for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.
Right to Object to Processing for Direct Marketing Purposes: You have the right to object to processing for direct marketing purposes.
Right to Withdraw Consent: If your Personal Information is processed on the basis of your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. If you consented to our use of your Personal Information in one of our customer’s apps, you can find more information on how to opt-out at complementics.com/opt-out.
Right to Erasure: You are entitled to have your Personal Information erased under specific circumstances, such as where you have withdrawn your consent, where you object to processing based on legitimate interests and we have no overriding legitimate grounds (see below) or where Personal Information is unlawfully processed.
Right to Data Portability: Where we are relying (as the legal basis for processing) upon your consent, or the fact that the processing is necessary to perform a contract to which you are party or to take steps at your request prior to entering a contract, and the Personal Information is processed by automated means, you have the right to receive all such Personal Information that you have provided us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.
Right to Restriction of Processing: You have the right to restrict our processing of your Personal Information (that is, allow only its storage) where:

you contest the accuracy of the Personal Information, until we have taken sufficient steps to correct or verify its accuracy;
where the processing is unlawful but you do not want us to erase the Personal Information;
where we no longer need your Personal Information for the purposes of the processing, but you require such Personal Data for the establishment, exercise or defence of legal claims; or
where you have objected to processing justified on legitimate interest grounds (see below), pending verification as to whether we have compelling legitimate grounds to continue processing.

Where your Personal Information is subject to restriction we will only process it with your consent or for the establishment, exercise or defence of legal claims.

If you wish to exercise your rights, please contact us at [email protected]. If you csonsented to our use of your Personal Information in one of our customer’s apps, you can find more information on how to opt-out at complementics.com/opt-out.

Right to Lodge Complaints. You have the right to lodge a complaint with a supervisory authority. However, we hope that you will first consult with us, so that we may work with you to resolve any complaint or concern you might have.

Contact Information

You can reach our data protection officer at [email protected]. Our UK representative is econtext.ai Ltd and can be reached at [email protected]. Our EEA representative is [email protected] -- and can be reached at [email protected]

Complementics GDPR Privacy Notice