Metricell Privacy Policy For CrowdScore

Last updated: 22nd January 2021

1. Who we are and why we collect data

This document describes how Metricell Limited (“Metricell”, “we”, “our” or “us”) a registered company in England and Wales, with company registration number 06052274 and its registered address at The Big Blue, 26 Foundry Lane, Horsham, RH13 5PX, United Kingdom, can collect, use and share data that you as a smartphone user may provide.

Metricell are a supplier of products and solutions that help Operators, Regulators and businesses within the Telecoms industry measure the performance of mobile network service and at times, Metricell will collect data samples from the devices of smartphone users through our partnerships with authorised third party mobile application providers.

Our primary goal is to make everyone Better Connected. Our expertise focuses on the testing and measurement of Mobile Operator network service and coverage across the world. The data we collect aims to support smarter, more appropriate improvements to mobile connectivity and these changes are based on customer experience data, network related performance metrics, service availability and device statistics. We collect data from all global regions, wherever there is a way to help improve mobile network coverage for all.

Metricell have created these terms with the goal of providing a clear and transparent understanding of Metricell’s practices, to help you understand the purpose and actions taken by Metricell in collecting data. These terms apply to any smartphone user that uses a mobile application, which has been released by an authorised Metricell partner, or a user of a mobile application, which has been released by Metricell.

2. Personal Data

Metricell do not collect any personal information that can be used to directly identify a smartphone user, or that can be directly attributable to a user. In addition, we do not collect information about race or ethnicity, political opinions, sexual orientation, actual or alleged criminal penalties, or any other information deemed as personal under GDPR. We take the necessary precautions to ensure Metricell and its customers cannot identify individuals from the data we collect.

Only data that is provided by you for; the purpose of direct contact from you to Metricell; directly for you (such as for the purchase of a service from Metricell); when you register for additional marketing information at www.metricell.com; or interact with any social media post that is from, about or includes us will be collected. Metricell is not responsible for the information you volunteer about yourself publicly or in any communication with Metricell.

3. How we collect data

Through our partnerships with third party mobile application providers (referred to as an Application Partners) Metricell collects data from the devices of the Application Partner user base. This data is provided to the Telecoms industry in the form of reports and geographical insights to identify how and where to improve their mobile network for everyone.

Metricell acts as the Data Controller and Data Processor as defined in the General Data Protection Regulation (GDPR) and we are committed to following the strictest privacy regulations around the world.

Metricell’s data collection software is integrated into the application by the Partner to collect data in the background of their applicable mobile application. As a user of the applications provided by the Application Partners, you will be providing Metricell with anonymous network measurement data when you download the applicable application and provide consent to allow data collection.

Application Partners are evaluated through robust security processes and authorised by Metricell only upon successful completion of these – this is to ensure both Metricell and the Application Partner treat data within the applicable laws (both data and Android / iOS) and in a secure manner. Only through validated applications released by the Application Partner will Metricell collect data.

Our partnerships with Application Partners are kept confidential and Metricell do not publicly disclose our partners without their explicit permission.

End users do not need to interact with the software nor change their behaviours with the application or device, other than answering the consent disclosure – our methods collect data without causing any impact to user experience. Furthermore, the impact to device performance from the data collection process is kept to an absolute minimum. Impact to device battery is kept below an additional 1% per day and additional data consumption is kept below 5MB over the course of a 30 day / 1 month period. Metricell are always looking for ways to further reduce these already minimal impacts.

Additionally, Metricell releases their own customer facing mobile applications, which will also collect data from users. These applications are subject to the same terms as listed in this Privacy Policy.

4. User consent

Data is only collected from users that provide their consent (permission) by accepting an in-app consent disclosure, which is displayed to all users within the partner’s application. This is traditionally indicated by the user making a positive action, such as clicking a tick box or selecting ‘Yes’ when presented with the in-app disclosure. By accepting these in-app disclosures, users are providing their consent to allow anonymised data collection.

Metricell works with partners to ensure these regulations are well met and audit these partners frequently. We also work with them to ensure any in-app consent disclosure is easily understandable by users, so that any decision to opt-in or opt-out is done so with a clear understanding by the user.

Users who wish to opt-out can traditionally do so through the following methods:

1. Opt-out of the in-app consent disclosure from within the mobile application. Users should consult the privacy policy and / or application settings for specific opt-out instructions.

2. Deny location permission for the application that collects data (be advised that doing so may affect certain functions of that app). Metricell are unable to collect data without location permissions being enabled. Please refer to Android and iOS guidelines for further information on application permissions.

3. If a user decides to do so, uninstalling the application will stop any data collection, as this also removes the Metricell software at the same time.

5. Types of data we collect

We commit to keeping users that provide data anonymous at all times. This means that data we collect through our software in partner applications cannot be used to directly identify individuals. It would require the addition of separate data sets, which are not held or accessed by Metricell, for Metricell or its trusted partners to identify individuals.

Data collection will only commence when the user of the partner application provides consent and opts-in to data collection in the application. By doing so, users agree to share the following data categories:

Device/Handset Details: To include device make/model and OS version. Metricell trusted partners use these details to identify network issues in relation to the type of device hardware and if they are experienced by specific device models.

Connection Details: To include network and / or service provider, SSID and BSSID (if using Wi-Fi), connected cell tower name / unique tower ID. These are used to provide Metricell trusted partners with a detailed comparison of their own network performance against competitors, with additional scope of Wi-Fi performance for those clients that also provide Home / Fixed Broadband services.

Network Quality: To include data speeds, connection ping (network latency) and mobile signal quality. These provide the core performance analysis of an Operator, with both indoor and outdoor performance comparisons, and includes the primary sets of data that Telecoms companies use to identify the problems within their network and where to make improvements.

Location: This will be both the network location and device location in the form of GPS. Without location, the above data would be obsolete. If a user denies location permission, then data collection is disabled. The location data is required to aggregated and plot the results of data collection on a visual map, to identify locations of good and bad network performance. It is not used to identify specific user locations or to identify specific users.

In some circumstances, actual data collected may differ depending on the agreement with the Application Partner. In addition, our Application Partners are spread across the world, which means in some regions, our data collection process may be stricter.

6. How data is stored

Metricell incorporate multiple methods to keep data safe and secure. Data is sent from application and is encrypted using secure HTTP protocols as it travels over the network and once received by the host server, it is securely stored and processed. Data may be stored within Metricell’s UK data centre or a secure third party environment with an approved and trusted Metricell partner. All data is stored only to an extent necessary for Metricell to fulfil its obligations to our trusted clients.

Metricell take thorough measures to ensure that any data provided by users of our Partner’s mobile applications is guarded against loss, theft or unauthorised use and access. These measures include physical, technological and administrative actions.

7. How data is shared

The main objective is to share analysis and evaluation of the network performance collected from user devices with both trusted potential parties and trusted clients, in support of improving the Telecoms industry. Metricell only shares data with companies that follow our strict privacy terms, and whom follow their own set of privacy terms.

Data can be shared in both raw and aggregated measurement forms. No data that we share includes personal data. Metricell can share data with the following parties:

With Customers: These are generally mobile network Operators, industry Regulators and mobile infrastructure companies. Data is provided to Metricell’s Telecoms clients in the form of reports and visual analysis using Metricell’s web-based data visualisation software. Only trusted companies, whom Metricell have a working relationship will be granted access to the data and software. At times, our clients may analyse the data within their own bespoke data software. We expect all Metricell clients to take the same approach as us to ensure data is secure and kept confidential.

With Application Partners: We obtain access to the data from your device through software incorporated in partner mobile applications, which the user has downloaded. At times, we will also provide the partner with access to the network data that is sourced from their own application users, to help them create the best application experience when considering the requirements from the mobile network.

With Employees: Our solutions require upkeep, maintenance and support and at times, our employees will access areas in which your data is stored.

With Auditors: Metricell may be required to provide auditors access to review our solutions and practices.

With Metricell Value Partners: The Metricell Value Partner program is a group of registered and approved Telecoms service providers, system integrators and IT specialists whom will often work in partnership with Metricell for the benefit of our current and potential Telecoms clients. These partners may require access to Metricell’s solutions in which data collected from you is accessed.

With Public Authorities: Through necessity, Metricell may need to disclose data we have collected from you with third parties, including but not limited to, the investigation into suspected illegal activities, the exercise or defence of legal rights illegal or requirements governed by applicable law.

The data is shared in aggregated form and any of the above groups will not have access to any personal data on users that provide data, nor will they be made aware of the partner applications, which have been used to collect and transmit the data.

Metricell may also create and publicly publish our own detailed reports, which uses insights gathered from collected data. As before, all data will be aggregated, confidential, with no ability to identify individual users. Further details on the variety of our work within the Telecoms industry can be found at www.metricell.com

8. Children's privacy

Metricell make every effort possible to protect the privacy of children under the age of 16. We do not knowingly collect any information from children under the age of 16.

We request that users who are under the age of 16 do not opt-in to data collection from our partner applications. Metricell also require that our Application Partners do not incorporate Metricell’s solution in any application that may be targeted directly for children. Additionally, we expect Application Partners to ensure that they make it clear to those under the age of 16 that they should not opt-in for data collection in any of their applications in which Metricell’s software is included.

9. Rights as a data subject

Data subjects have the following legal rights in respect of their personal data:

1. Right to Access: the right to request and obtain confirmation from the controller as to whether or not personal data concerning the data subject is being processed.

2. Right to Erasure: the right to request erasure of the personal data regarding the data subject.

3. Right to Rectification: the right to request changes to inaccurate personal data regarding the data subject.

4. Right to Data Portability: the right to receive the personal data concerning the data subject, which they have provided the data controller based on consent or as part of a contractual obligation. This must be in a machine-readable format.

5. Right to Object: the right to object at any time to processing of personal data concerning the data subject.

To make a request, please send an email to contact@metricell.com with “Metricell Data Rights” in the subject line.

Due to the nature of the data collection by Metricell, we have taken all appropriate measures to protect and remove the personal data of every data subject, which is why all users are anonymised. Due to this, it may be impractical to satisfy specific requests, as it may be inherently difficult or even impossible, to associate data with a specific data subject. The above legal rights are subject to various conditions and exceptions.

In the interest of ensuring user security and privacy, please be aware that Metricell take widespread actions to ensure that the identification of any users in our data is difficult. This means it is intentionally difficult to identify you or any user from within our data. Therefore, some restrictions are in place when it comes to requests made to Metricell.

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 contact@metricell.com 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. Notes and changes on this policy

Metricell will often update and amend this policy, in line with changes to legal requirements or otherwise. Please refer to the “Last Updated” section at the top of this document. It is advised that you refer to this document in the future frequently for any changes that may have been made.

Please be advised that this policy does not incorporate the handling of Metricell employee data or customer contact data that is obtained through regular course of business. Customers may provide contact details, such as name, email address and contact number during discussions with Metricell. Metricell have other policies in place that refer to these details.

12. Questions and contact

You can contact Metricell with questions on these terms at contact@metricell.com - please be aware that we recommend that only information that you are happy to share with Metricell be sent. Due to the nature of our anonymised data collection, responses may be limited when questioning data relating to a mobile device.

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