Privacy Policy

Privacy Policy

Background

StreetHawk is an automated communication platform for Mobile and Tablet applications (Apps). The StreetHawk Platform is made available by Dealsta PTY LTD ABN 161 497 13342 (“StreetHawk”, “us” or “we”) to Application Owners/Developers and their delegates (“App Owner”, “developer”, “customer”). The intended audience (“you”) for the StreetHawk Privacy Policy is any:

  • end users of an App that uses the StreetHawk Platform that may have questions.
  • App Owners, customers or other people who communicate with us

The components of StreetHawk are:
(i) the StreetHawk Platform, documentation, sample code and any fixes, updates and upgrades provided;
(ii) the StreetHawk Application Programming Interface (“StreetHawk API”), the StreetHawk Libraries necessary for an App Owner to install and deploy in order to make use of StreetHawk functionality;
(iii) the StreetHawk Console, analysis, testing, messaging tools and administrative console; and
(iv) a variety of reports related to the behaviour and usage patterns of users using an App (“Reports”). The StreetHawk Platform may be used by an App Owner for the purposes of app content, communications, monitoring, campaign generation & reporting, messaging, push notifications and analytics according to the StreetHawk Plan to which they have subscribed.

App Owner Responsibility

Often the data that is stored in the StreetHawk Platform & Console is at the discretion of the App Owner (developer) and they may already have a Privacy Policy or Terms of Use that detail how your data is used. You may also wish to confirm with your App Owner if they have subsidiary agreements relating to data sharing.
To provide value to these Apps our SDK may (subject to Application Developer design decisions) send proximity, preferences and usage data as detailed below.

General

ANONYMITY: StreetHawk provides many features to customer Apps that do not require personal identity information. It is the application developer’s option to provide additional information to the StreetHawk platform. The StreetHawk solution is designed to be able to still engage with App users without asking them to provide personal details – often its HOW the user uses the App rather than WHO they are.

DEVICE ANONYMITY: Over the years there has been concerns over Apple iOS’s UDID being collected and its impact on privacy. StreetHawk does not collect this.

LOCATION OPT-IN: It is important to understand that each user of a mobile application on either Android or IOS has the opportunity to opt-in to specific features of the application as provided by the developer of the application and the operating system. For example on IOS it is impossible to use “location-services” without the user accepting an opt-in prompt at the time the application attempts to enable location. Further, the user always has the option to disable the location services using the IOS system settings or deleting the application.

We know that privacy is an important concern for just about everyone using location-based services, and that the places you go can often be sensitive – we want to advise you how this information is used on the StreetHawk platform subject to the points made in the previous paragraph. Below explains how we collect, use, store and disclose your personal information.

Personal information, as defined in the privacy legislation, is information, or an opinion, in any form, and whether true or not, about an individual whose identity is apparent or can reasonably be ascertained from the information or opinion.

Based on the conditions described in “LOCATION OPT-IN”,”DEVICE ANONYMITY” and “ANONYMITY”, the StreetHawk platform therefore may not collect ANY personal information. The best way to ascertain this is to directly request this information from your App Owner.

How we collect personal information

Information is collected and aggregated on 2 levels:

  • “Install ID” – an abstract identifier created by StreetHawk for each individual installed application per device (a phone, tablet etc)
  • “sh_cuid” – an abstract identifier made available by StreetHawk for each individual “user” that may be optionally used by the App developer. Typically this is done to link the user with their own system. This sh_cuid could remain abstract or an App Owner/developer may elect to use something like an email address – this is their choice.

Other data is then attached to these identifiers based on the customer application implementation (the developer chooses to “tag” a profile with data based on a user behaviour/information – for example:

  • a ‘button-click’
  • a gender could be tagged to a ‘sh_cuid’ without linking that with any personally identifiable information.

A developer will typically do this in order to provide some automation, segmentation or reporting.

Therefore, we only collect information about you when the App Owner supplied to us directly, and/or when you install & interact with the App on a voluntary basis. For example, we will collect information when:

  • You start your App – which approximately tells us where you are (IF the developer has opted to use our location services AND you have opted-in to that feature).
  • You do an action that a customer’s application developer logs, for example:
    • the “tag” activity discussed above
    • entering and exiting App screens
    • backgrounding the App
  • Your app ‘crashes’. This is actually non-personalised information to tell us the code location and nature of the crash that occurred.
  • iBeacons are a subset of location technology that your App developer may have chosen to use. If the developer has opted to use our iBeacon services AND you have opted-in to that feature AND there is an iBeacon that the developer has specifically registered, this may result in this being sent to the StreetHawk Platform. iBeacons may nor may not be related to geographic locations, therefore it is best you request this usage from your App developer.

For a full list of data that can be collected by StreetHawk, please refer to our API documentation, specifically this section: http://api.streethawk.com/v1/docs/installs.html

Location & Usage Detail

We do not disclose a history of where you have been but the App Owner does have access to the most recent approximate (see below) location IF the developer has opted to use our location services AND you have opted-in to that feature).

Determining Location

We use the location information from your phone to tailor your App experience if your App Owner chooses to implement “Campaigns” or use “Geofences” within their application. In order to provide this capability when you are `out and about’ we track your current location within a 500 metre (approximate) radius when operating in the background. We take 100m (approximate)location samples when a StreetHawk enabled App is foregrounded to correlate Geofence location for footfall or proximity.

Facebook and Email

StreetHawk enables the App Owner/developer (at their discretion) to store/remove this data on the StreetHawk Platform. Please refer to http://api.streethawk.com/v1/docs/tagging.html and ask your App Owner if this feature is being used. Of course, when you share this information in the App – it will be seen by your Facebook community or email list.

Outside the StreetHawk Platform

We also collect personal information about you in the normal process of doing business:

  • Communicate with us via email, our website or completing a survey
  • Enter a promotion or competition or respond to an offer

The personal information we are likely to collect from you is derived from the information you provide to us, and what you do when you communicate with us. Information can include such things as your name, address, mobile phone number, email address along with transactional information.

We do not collect or retain credit card numbers.

It is our policy not to sell or pass this information to any other organisations unless we are required to do so for legal reasons.

Blogs, bulletin boards, reviews and chat rooms

We may provide areas on our website and app where you can post information about yourself and others and communicate with others or upload content (e.g. pictures, videos, audio files, etc.). Such postings are governed by our Terms of Use. In addition, such postings may appear on other websites or when searches are executed on the subject of your posting. Also, whenever you voluntarily disclose personal information on publicly-viewable web or app pages, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your personal information.

What we collect other than personal information

Site and mobile use information
When you use our website we may collect non-identifiable information including your client IP Address, the App Owner’s server address, the type of internet browser you use, the date and time of your visit, the particular pages and items you accessed and the information you download. This information may be used by us (or third party contractors) in anonymous aggregated form for statistical purposes so that we can monitor and improve the quality of the website and app.

We may use standard Internet and mobile technology, such as web beacons, GPS, links and other similar technologies, to track your use of the StreetHawk website or platform. We also may include web beacons in promotional or other e-mail messages or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customise the services we offer you and to measure the overall effectiveness of our online communications, advertising, content, programming or other activities.

Cookies
A cookie is a small file that stores information on your computer’s hard drive regarding your Internet web browsing activity and then reports this information back to the website that created the cookie. Amongst other uses, cookies enable websites to be customised for individual users. 

We may use cookies to personalise your visit to our website. If you do not want to accept cookies, you can adjust your internet browser to reject cookies or to notify you when they are being used. Rejecting cookies may limit the areas of our website that you are able to access and may impact certain functions of our website, such as storing items in your shopping basket between visits.

How we use your personal information

We generally use your personal information to provide a personalised service to you, and more generally to conduct a business relationship with you. We also use the information you provide to develop and improve our products and services. 

If you enter a competition or promotion, we will use your personal information to conduct that competition, promotion or offer and to comply with any regulatory requirements (such as notifying State/Territory lottery departments and publishing winner(s) names if required). 

We may also use your personal information to notify you about changes to our products or services, new products and future offers in which we think you may be interested. If you prefer not to receive such information, please follow the unsubscribe instructions contained in the particular communication.

Your choices about collection and use of your information

You can choose not to provide us with certain information, but that may result in you being unable to use some features because such information may be required in order for you to have personalised response.

Disclosure to third parties

We may disclose your personal information to third parties in the following circumstances:

  1. To third parties whom you have been informed of at the time of collection
  2. To our suppliers or distributors or other third parties to whom disclosure is necessary to fulfil the purpose for which the personal information has been collected
  3. To any entity to which we are required or authorised by law to disclose such information
  4. We use Amazon AWS hosting for our servers and have good reason to believe data is not accessed by their staff or other entities – however recent events reported in the press indicate that some government agencies do have access beyond the scope of (3).
  5. To our professional advisors

Security

We take appropriate security measures (including physical, electronic and procedural measures) to help safeguard your personal information from unauthorised access and disclosure. For example, only authorised employees are permitted to access personal information, and they may do so only for permitted business functions. In addition, we use firewalls to help prevent unauthorised persons from gaining access to your personal information.

We want you to feel confident using StreetHawk to transact business. However, no system can be completely secure. Therefore, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information, searches, or other communications will always remain secure. Users should also take care with how they handle and disclose their personal information and should avoid sending personal information through insecure email.

Children’s privacy

StreetHawk is a general audience platform, and we do not knowingly collect personal information from children under the age of 13. You may wish to confirm with your App Owner.

Accessing and correcting your personal information

You may request access to, update or change personal information that we hold about you by contacting our Privacy Officer in writing at privacy@streethawk.com. However we suggest that you contact your App Owner first as they likely have additional data collected when you use their App.

Australian Privacy Principles

Currently StreetHawk is classified as a “small business operator” and therefore is not covered by the Privacy Act 1988 or the Australian Privacy Principles (APPs) contained within. We are however committed to ensuring the privacy of your personal information and the above Policy addresses many of the 2014 APPs.

We reserve the right to modify this Policy at any time, and without prior notice, by posting amended terms on this website. Your continued use of the StreetHawk Platform indicates your acceptance of the amended Policy.