Privacy Policy
Everything you need to know

1. Who we are

This Privacy Policy describes how Teragence Limited (“Teragence”, “we,” “us” or “our”), collects, uses, and shares data (personal data as well as non-personal data, as defined by the GDPR) when you allow us access to data on your device in connection with your use of a mobile application operated by one of our partners (“Partner”).

We request access to data from your handset to measure the availability, signal quality and overall network quality of mobile communication networks (“our Services”), as well as other services such as device and operator market share analysis.

Teragence is responsible for the control and processing of data that we collect from your device. If you have any questions or concerns about Teragence’s use of data, please contact us at [email protected].

This Policy aims to inform you about our privacy practices and to ensure that you understand what data we collect and process and the purposes for which we collect it.

Our mission is to analyse and review the signal quality, availability, service coverage, performance and market share of mobile networks, operators and handsets all over the world. We obtain this data by collecting measurements from users of mobile devices.

2. How we collect and use data

We collect data from your mobile device both when you are using our Partner’s app and when it is closed.

From time to time we collect selected information from your device including location data (which include GPS coordinates or similar information regarding the location of your device), network type, network operator, cellular and WiFi signal strength and quality, and the identifiers of connected cell towers and WiFi routers (including both BSSID and SSID). We also runn small tests which download or upload data within our software. We do not monitor the content of your data or voice usage nor do we monitor where and how much data you consume or who you communicate with.

We do not collect any data on the apps installed on your device or the usage of these apps. The goal of collecting the above data is to measure the quality of the network your device is connected to, assess handset performance and analyse network operator and device market share.

We can also measure some internal device conditions – such as battery and screen state. The goal of collecting this data is to understand how instantaneous device conditions affect experience of mobile networks.

To better understand the impact of devices, we can collect data on your device hardware such as the model, manufacturer, and manufacturers and models of sub-components (such as the cellular radio) and the capabilities of these components (for example the number of cores on the CPU). Similarly, to understand differences caused by software, we can collect information on the mobile platform version used and whether custom ROMs or Android skins are installed. The goal of collecting this data is to understand how device characteristics impact the performance of mobile networks.

We do not collect or transmit any persistent individual identifiers from your device such as MAC-address, IMSI/EMEI code or advertising-ID. We assign your device with its own internally-generated ID, but this ID is stored separately from the measurements we collect. This prevents us or anyone else to use the data to identify any single individual.

3. Applications of the data

Measurements that we take from the mobile devices of individual network users enable us to create a detailed picture of the service availability, quality and performance of mobile communication networks across different locations, networks and moments in time. We publish some of the statistical data that we generate and we provide it to our customers (such as network operators , regulators and other ecosystem players) to help them gain better insight in various network and handset performance metrics and market shares.

We do not use the data for direct marketing targeting, movement analytics, behavioral profiling or segmentation.

4. Legal basis for processing data

We collect and process data based on your consent. If you give your consent for accessing your mobile data to take measurements, you can withdraw it through the personal settings on the Partner’s app.

5. How we share data

i. Joint Controllers. We share some of the raw measurements that we collect from users’ mobile devices with some of our customers under the terms of data licence and sharing agreements. While the data we share with our customers may contain location data, this will always be dissociated from individual, persistent user-ID’s, ensuring that no personal data is shared. Our customers are permitted to use the data for the purpose of analysing it and generating aggregated data relating to the performance of networks and equipment and to assess the market shares of devices and operators and to use aggregated data in their sales activities. Our customers cannot use data to communicate with you or to influence you or to profile or track individual users. Neither do we. Our customers are required to keep the data confidential and to use appropriate means to protect it. Our customers have access to data such as location data of users to enable them to analyse the data and create statistical information based on the aggregation of data from numerous users.

ii. Our Partner. We obtain access to data from your mobile device through software incorporated in our Partner’s mobile application which you download onto your device. We might share with our Partner any of the data we collect from your device. Our Partner is permitted to use the data for the purpose of analysing it and generating aggregated data relating to the performance of networks and equipment and to assess the market shares of devices and operators and to use aggregated data in their sales activities. The Partner can not use this data to communicate with you or to influence you or to profile or track individual users.

iii. Service Providers. We may share datasets containing your data with third-party service providers that perform services on our behalf in connection with our Services, such as cloud service providers or third party analytical service providers. Where your information is shared with such third parties, we ensure that the third party service provider will deal with your information only on our behalf and on our written instructions and solely for Our benefit (and not for its own benefit).

iv. Business Change. If we become involved in a merger, consolidation, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganisation, liquidation, dissolution or other transaction, or if the ownership of all or substantially all of our business otherwise changes, we may share or transfer databases containing data of users to successor party or parties in connection with such transaction or change in ownership or legal structure.

v. Necessary Disclosure. Regardless of the choices you make regarding your information and to the extent permitted or required by applicable law, we may disclose information to third parties to: (i) enforce or apply the terms and conditions of our Services; (ii) comply with laws, subpoenas, warrants, court orders, legal processes or requests of government or law enforcement officials; (iii) protect our rights, reputation, safety or property, or that of our users or others; (iv) protect against legal liability; (v) establish or exercise our rights to defend against legal claims; or (vi) investigate, prevent or take action regarding known or suspected illegal activities; fraud; our rights, reputation, safety or property, or those of our users or others; violation of the Terms of Use, our policies or agreements; or as otherwise required by law.

6. How we protect data

We take certain measures to protect personal data collected through the Service against loss, theft, and unauthorised access, use, disclosure, destruction or modification. These include physical, technological and administrative measures.

7. How long we keep data

Data contained in the sets of measurements of mobile network signal performance is held for an unlimited period of time as it is required for the production of statistical data over different periods of time and to compare performance data between different time periods.

8. Where we process the data

We operate from the United Kingdom (UK) and our data processing activities take place predominantly in the UK. We store and otherwise process data through third party cloud service providers and other IT service providers which may be located or which may operate in other countries, including countries which do not guarantee the same level of protection to privacy as the UK. Some of our customers to which we license data (see section 5(a) above) also receive data from us for processing in countries outside the UK or the EU. When transferring data records from the UK to a country outside the EU which does not provide an adequate level of protection to privacy rights, we put in place appropriate safeguards including data transfer agreements on the terms approved by the EU Commission.

9. EU Data Privacy Rights

Users based in the European Union have the following legal rights in respect of their personal data:

a. The right to require Teragence to confirm whether or not any personal data is being processed, the purpose of any such processing, the recipients of any information that has been disclosed, the period for which their information is to be stored and whether any automated decision-making processes are used in relation to their information;

b. The right to require Teragence to rectify inaccurate personal data without undue delay;

c. Where Teragence has relied on the ‘consent’ basis for processing any personal data, the right to withdraw their consent at any time. This right to withdraw consent does not affect the lawfulness of any processing based on consent before its withdrawal;

d. The right to request the erasure of their personal data. You can make a request for erasure where:

i. the personal data is no longer necessary in relation to the purpose for which it was collected;

ii. where the processing of the personal data is based on the user’s consent (and the other circumstances described in the ‘Legal Basis for Processing Your information’ and ‘How We May Share Your information’ sections above no longer apply), if the user withdraws his or her consent; or

iii. where the personal data is processed by Teraence solely on the basis of our ‘legitimate interest’ referred to in paragraph 8(a) (and the other legal basis set out in paragraph 8 do not apply), if the user objects to the processing of his or her personal data and there are no overriding legitimate grounds for the processing (such as, for example, where the processing of the data is required to meet statutory obligations or for the defence of legal claims). Where Teragence has disclosed the personal data of a European Union user to a third party and the user requests the erasure or rectification of the data, Teragence will take all reasonable steps to inform the third party of such request;

e. The right to require Teragence to restrict its processing of a user’s personal data in certain circumstances, such as where the accuracy of that data is disputed or an objection has been raised. In such circumstances, Teragence will only process that personal data with the express consent of the user, or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest;

f. Where data is processed based on user’s consent or to fulfil a contractual obligation, the user has the right to receive his or her personal data from Teragence in a structured, commonly used and machine-readable format;

g. The right to object to the processing of personal data where: i. Teragence relies solely on the ‘legitimate interest’ basis for processing that data, in which case we will be legally required to stop processing the user’s personal data unless we have compelling legitimate grounds for the processing which override the user’s privacy rights and interests; or ii. the information is used for direct marketing purposes, in which case we will immediately stop processing the user’s personal information for such purposes;

h. Users have the right to lodge a complaint with the data protection supervisory authority of the EU member state where the user resides. The above legal rights are subject to various conditions and exceptions including where the data is used for statistical or scientific research purposes and the exercise of the right would prevent such purposes from being attained or would seriously impair their attainment.

10. CALIFORNIA PRIVACY RIGHTS

Under California Civil Code Section 1798.83, if you are a California resident and your business relationship with us is primarily for personal, family or household purposes, you may request certain data regarding our disclosure, if any, of information to third parties for the third parties’ direct marketing purposes. To make such a request, please send an email to [email protected] with “Request for California Privacy information” in the subject line. You may make such a request up to once per calendar year. If applicable, we will provide to you via email a list of the categories of information disclosed to third parties for their direct marketing purposes during the immediately-preceding calendar year, along with the third parties’ names and addresses. Please note that not all personal data sharing is covered by Section 1798.83’s requirements.

11. Application

This Policy relates to all data, whether general data (“data”) or personal data, as defined in the GDPR. i.e. data about you, an individual, from which you can be identified. We reserve the right to generate anonymised and aggregated data extracted out of any databases containing your personal data and to make use of any such anonymised and aggregated data as we see fit (including publishing such data and sharing it with third parties).

12. Privacy Policy Changes

We may update this Policy from time to time, and the updated version of this Policy will be effective upon posting on the OpenSignal Services. Please check this page to review the most up-to-date version of this Policy.

13. Questions /Getting in touch

If you have any questions regarding this Privacy Policy or if you wish to make a request in accordance with paragraphs 10 and/or 11 above, you may email us at [email protected] or contact us by mail addressed to:

Teragence Ltd
35 Ellesmere Road
London
NW10 1LJ UK

Last updated 04 October 2018