Ad Hoc Labs Privacy Policy
This Privacy Policy was last updated on July 1, 2020.
Our Policy
This Privacy Policy describes the privacy practices of Ad Hoc Labs, Inc. (“Ad Hoc Labs”, “we”, “us” and/or “our”) with respect to our use and disclosure of the information that we collect about users of the Burner mobile application, the website, burnerapp.com, the Firewall mobile application, related services, and any other services where the Privacy Policy is shown (collectively, our “Services”).
Before you use or submit any information through or in connection with our Services, please carefully review this Privacy Policy. By using any part of our Services, you understand that your information will be collected, used, and disclosed as outlined in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use our Services.
The Privacy Policy describes:
Information We Collect About You
Our Use of Online Analytics and Tailored Advertising
Information Related to Children Under the Age of 13
Integrating Third Party Services within the Services
Users From Outside the United States
Information Notice for California Residents & Privacy Rights
Information We Collect About You
In order to provide and improve upon our services and better market our services to customers, we receive and collect information about you in various ways. When you interact with us through our Services, we collect information in multiple ways, including when you provide information directly to us; when we passively collect information from or about you, such as from your browser or device; and when we collect information about you from third parties. We may combine all of the information we collect from or about you from these various sources.
Information You Provide Directly to Us: In order for you to use our Services, we may collect limited information about you when you voluntarily provide such information, including your mobile phone number. In some other limited cases, we may also collect audio information (such as audio recordings if you do not opt-in to voicemail customization or speech-to-text requests). In some other limited cases, we may also collect your name, postal address, email address, collect, payment information (through our payment processors), gender, race, age ranges, education information, employment information, and other information that identifies or can be reasonably associated with you. Wherever Ad Hoc Labs collects personal information, we make an effort to provide a link to this Privacy Policy. We will use, transfer and disclose this information as described in this Privacy Policy.
Unsolicited submissions such as ideas that you submit for new products or modifications to existing products, and any other unsolicited submissions shall be deemed to be non-confidential and Ad Hoc Labs shall be free to reproduce, use, disclose, distribute, and exploit such unsolicited information without limitation or attribution.
Information that is Automatically Collected: We also collect information through automated and technical means as you browse our website, use our mobile applications, or otherwise use our Services.
Device and Online Usage Information. Like most providers of websites and mobile applications, when you interact with our Services, we receive and store certain information that is collected passively using various technologies. This information includes IP address, Media Access Control (MAC) address, device type (e.g., Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language and Internet browser type and version, the pages you view in our Services, pages referring you to our Services, when you use our Services, mobile carrier, time zone, device identifiers (including Apple’s IDFA and Android’s advertising ID), and the sites on which you actively use our Services.
SDKs, Cookies and Other Tracking Technologies. In operating our Services, we and our service providers also collect data about your use of our Services through the use of a variety of tracking technologies, including SDKs, cookies, tracking pixels, and web server logs, as described below.
We may use SDKs on our mobile applications that leverage identifiers provided in mobile operating systems like iOS and Android to (i) inform, optimize, and serve our marketing to you based on your use of the mobile applications; and (ii) provide analytics on the performance of our marketing.
We may use cookies, tracking pixels and, webserver logs for the same general purposes as SDKs, but on our websites, rather than in our mobile applications. Web server logs provide data on how users behave on our website, which allows us to optimize our website performance. A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access our Services. Our cookies help provide additional functionality to our Services and help us analyze usage of Services more accurately. For instance, our Services may set a cookie on your browser that allows you to access our Services without needing to remember and then enter a password more than once when using our Services. Tracking pixels (sometimes referred to as web beacons or clear GIFs) are electronic tags with a unique identifier embedded in websites, online ads and/or emails, and that are designed to provide usage information like ad impressions or clicks and measure popularity of our Services and associated advertising, and to access user cookies. We and our service providers may also include Web beacons in email messages, newsletters and other electronic communications to determine whether the message has been opened and for other analytics, personalization and advertising purposes. As we and our service providers adopt additional technologies, we may also gather additional information through other methods. Please consult the "Help" section of your browser for more information about how to control cookies and other tracking technologies (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). Please note that by blocking any or all tracking technologies, you may not have access to certain features or offerings of our Services.
Information We Collect from Third Party Sources: We may obtain additional information about you from third parties such as partners, social networks (when you post on our social media pages or message us through a social media platform), and others. We may combine information that we collect directly from users with information about you that we obtain from such third parties and information obtained from such third parties and information derived from any other service we provide.
Using Your Information
Ad Hoc Labs uses the information you provide in a manner that is consistent with this Privacy Policy. If you provide information for a certain reason, we may use the information in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the information you provide to answer your question or resolve your problem. Also, if you provide information in order to obtain access to our Services, we will use your information to provide you with access to such services and to monitor your use of such services.
Ad Hoc Labs and its subsidiaries and affiliates (the “Related Companies”) also use your information to help us improve the content and functionality of our Services; to better understand our users and to improve our Services, including to develop new features or services; for user lookalike modeling, marketing, and advertising; for analytics, research, and reporting; to comply with the law and protect the safety, rights, property, or security of Ad Hoc Labs, our Services, our customers, and the general public; and to enforce our Terms of Service. Ad Hoc Labs and its Related Companies may also use this information to communicate with you regarding the Services or to tell you about services we believe will be of interest to you.
If Ad Hoc Labs intends to use any information in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the information is collected.
Sharing Your Information
Ad Hoc Labs is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your information with certain third parties without further notice to you, as set forth below:
911 Calls and Requests for Emergency Assistance. NOTE THAT THE SERVICE CAN NOT AND SHOULD NOT BE USED FOR 911 OR EMERGENCY CALLING. However, if you attempt to contact emergency services via the Service, we may provide information about you to a public safety answering point; emergency medical service provider or dispatch provider; public safety, fire service, or law enforcement official; or hospital emergency or other medical care facility. As permitted by law, we may also disclose information without a user’s consent in an emergency situation involving risk of death or serious physical harm, such as to a user’s legal guardian or members of a user’s immediate family or to database management services or information providers solely to assist in delivering emergency services.
Affiliates and Subsidiaries: We may also share your information with our affiliates and subsidiaries for purposes consistent with this Privacy Policy.
Agents, Consultants, and Similar Third Party Service Providers: Ad Hoc Labs, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases, and processing payments. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, or due diligence related in anticipation of such an event, information that we have retained about you may be part of the transferred assets or anticipated transaction.
Consent: We may also disclose your information to any third parties based on your consent to do so.
De-identified or Aggregated Data: When you interact with Ad Hoc Labs through our Services, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, is not intended to specifically identify you. Ad Hoc Labs may store such information itself or such information may be included in databases owned and maintained by Ad Hoc Labs affiliates, agents or service providers. Our Services may use such information and pool it with other information to track, for example, the total number of visitors to our Services, the number of visitors to each page of our Services, the domain names of our visitors' Internet service providers and how our users use and interact with our Services. Also, in an ongoing effort to better understand and serve the users of our Services, Ad Hoc Labs sometimes conducts research on its customer demographics, interests and behavior based on the information provided to us. This research may be compiled and analyzed on an aggregate basis. Ad Hoc Labs may share this de-identified or aggregate data with its affiliates, subsidiaries, agents and business partners, but this type of information is not intended to identify you personally. Ad Hoc Labs may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
Legal Requirements: Ad Hoc Labs may disclose your information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation or valid legal process; or (ii) act in urgent circumstances to protect the personal safety of users of our Services or the public.
Our Use of Analytics and Interest-Based Marketing
A. Analytics. We and our service providers (including Google through its provision of Google Analytics services) may also collect analytics data through our Services to collect and analyze that data and to engage in auditing, research, improvement of our Services, and reporting. The information (including your IP address) collected by various analytics technologies described in the “Cookies and Other Tracking Technologies” section above will be disclosed to or collected directly by these service providers, who use the information to help us evaluate your use of our Services, including by noting the third-party website from which you arrive to our Services, analyzing usage trends, assisting with fraud prevention, and providing certain features to you. One of our analytics providers, Google, provides tools to prevent it from using your information for analytics. If you wish to use this tool offered by Google, you may install the Google Analytics Opt-out Browser Add-on by clicking here.
B. Interest-Based Marketing. When you use our Services, Ad Hoc Labs may market to you our products, services and related features to improve and personalize your use of our Services. We may personalize this marketing based various factors such as the features you are using, demographic and geographic data, and other information collected. This marketing may be based on your current activity on our Services or your activity over time and may be tailored to your interests.
In order to provide this interest-based marketing, we may use third party service providers who may place cookies or other tracking technologies, such as mobile SDKs on your computer browser, mobile phone applications, or other device to collect information about your use of our Services in order to provide interest-based marketing to you. These providers may only use this information in order to help us provide interest-based marketing of our services to you.
We neither have access to, nor does this Privacy Policy govern, the use of cookies and other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access our Services by non-affiliated, third-party service providers. As described below, these providers may offer you a way to opt-out of the collection of information that is used for our interest-based marketing to you. We cannot guarantee that these instructions will not change, or that they will continue to be available; they are controlled by each third-party service provider, not us.
If you are interested in more information about interest-based marketing and how you can generally control cookies and other tracking technologies that deliver our interest-based marketing, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s (DAA’s) Consumer Opt-Out link or TrustArc’s Advertising Choices Page to opt-out of receiving interest-based marketing from companies that participate in those programs.
We may target users with Google accounts with Personalized display advertisements. You can opt-out of Google Analytics for display advertising or customize Google display network ads by visiting the Google Ads Settings page. You will need to log in to Google via the Sign In link if you are not already logged in when you visit that page.
Facebook also offers settings that may control what information Facebook uses about you or your device activity for advertising purposes. For more information, you will need to log in to Facebook via the Sign In link and go to Settings > Ads > Ad Settings (web) or Ad Preferences > Ad Settings (app).
Please note that the above opt-outs refer only to interest-based marketing. You may still receive other forms of non-interest-based marketing even if you opt-out as described above.
Notice Concerning Do-Not-Track Signals
Do Not Track (“DNT”) is a privacy preference that you can set in certain web browsers. We do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means and what it means to comply with DNT. You can learn more about Do Not Track here.
Your Choices
If you receive marketing communications from us, each marketing communication we send you will contain instructions permitting you to "opt out" of receiving future marketing communications. Note, however, that as user of the Services you cannot opt out of some administrative communications that are reasonably necessary to the Service, such as billing or service notifications. In addition, if at any time you wish not to receive any future communications or you wish to have your name deleted from our mailing lists, please contact us as at legal@adhoclabs.co.
To keep your information accurate, current, and complete, please contact us as at privacy@adhoclabs.co. We will take reasonable steps to update, correct, or delete your information upon your request.
One of the features of our Services allows you to "burn", or delete, individual phone numbers from your phone at any time, as well as automatically upon the expiration of a number that you elect not to renew. If you delete a number via this “burn” feature, we delete all of its history and message content from the application on your phone and from our primary working server. Backup copies of this data are not immediately deleted. Additionally, some aspects of user history are maintained for longer periods of time on our primary working server so that we can reconcile our records and manage our business. Please be advised that we have no control over data that may be captured by third parties through your use of our Services, including but not limited to your carrier, internet service provider, platform providers like Apple or Google, and third-party vendors we may rely on to perform our Services, except that we will not disclose personal information to third parties other than as permitted in this Privacy Policy.
If you would like to delete your entire account history, please contact us via email at privacy@adhoclabs.co or through the webform.
Information Related to Children Under the Age of 13
Ad Hoc Labs’s Terms of Service prohibit use of our Services by children under the age of 13, and Ad Hoc Labs and does not knowingly collect “personal information” (as defined by the Children’s Online Privacy Protection Act) from children under the age of 13. If you are under the age of 13, please do not use or submit any “personal information” through our Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to use our Services. If you have reason to believe that a child under the age of 13 has provided “personal information” to Ad Hoc Labs through our Services, please contact us, and we will take reasonable steps to delete it as soon as possible.
Links to Other Web Apps
This Privacy Policy applies only to our Services. Our Services may contain links to other web applications not operated or controlled by Ad Hoc Labs (the “Third Party Apps”). The policies and procedures we describe here do not apply to the Third Party Apps. The links from our Services do not imply that Ad Hoc Labs endorses or has reviewed the Third Party Apps. We suggest contacting those Third Party Apps directly for information on their privacy policies.
Integrating Third Party Services within the Services
Some features of our Services may allow you to enable various online third party services, such as social media and networking services (“Third Party Services”), to be directly integrated into your Ad Hoc Labs experience. By directly integrating these services, we make your online experiences richer, and more personalized. To take advantage of these features, we may ask you to provide us login authorization for the relevant Third Party Services. By enabling such Third Party Services, you are allowing us to pass your information to these service providers for this purpose. When you add a Third Party Service account to the Service, we will collect your login information and other relevant information necessary to enable the Service to access that Third Party Service and your data contained within that Third Party Service. However, please remember that the manner in which Third Party Services use, store and disclose your information is governed solely by the policies of such third parties, and Ad Hoc Labs shall have no liability or responsibility for the privacy practices or other actions of any Third Party Service that may be enabled within our Services.
Users Outside the United States
Our Services are hosted in the United States, governed by United States law, and targeted to individuals located in the United States. If you are using our Services from outside the United States, please be aware that your information may be transferred to, stored and processed in the United States where our servers are located, and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as, or just different from, those in your country. By using our Services, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Privacy Policy.
Information Notice for California Residents & Privacy Rights
If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).
Categories of personal information we collect and disclose. Throughout this Privacy Policy, we discuss in detail the specific pieces of personal information we collect from and about users. The sources for that information are provided in the “Information We Collect About You” section above.
During the 12 months leading up to the effective date of this Privacy Policy, we made the following disclosures of personal information about Californians:
| Category of personal information | Categories of third parties to which it was disclosed |
| Contact information and identifiers, such as device ids, name, address, email address. | Affiliates and subsidiaries; transactional support providers; marketing and advertising services; providers of technical services; and governmental entities. |
| Demographics, such as your age and gender. | Same as first row, except not to marketing and advertising services or governmental entities. |
| Financial information, such as credit card information. | Same as first row, except not to marketing and advertising services or governmental entities. |
| Commercial information, such as transaction history. | Sane as first row. |
| Internet or other network or device activity, such as browsing history or Services usage. | Sane as first row. |
| General geolocation information, such as your city and state based on IP address. | Affiliates and subsidiaries and providers of technical services. |
| Professional or employment related information, including education information | Same as first row, except not to marketing and advertising services or governmental entities. |
| Audio data, such as audio recordings if you opt-in to voicemail greeting customization and speech-to-text requests. | Same as first row, except not to marketing and advertising services or governmental entities. |
| Inference data, such as information regarding your preferences and other inferences we create based on the information you provide us and other personal information we hold. | Same as first row, except not to marketing and advertising services or governmental entities. |
| Other information that you provide us that identifies or can be reasonably associated with you. | Same as first row. |
How we use these categories of personal information. We and our service providers may use the categories of personal information we collect from and about you for the following business purposes and commercial (as those terms are defined in applicable law):
Our or our service provider’s operational purposes;
Auditing consumer interactions on our site (e.g., measuring ad impressions);
Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;
Bug detection and error reporting;
Customizing content that we or our service providers display on our Services;
Providing our Services (e.g., account servicing and maintenance, customer service, advertising and marketing, analytics, and communication about our Services);
Improving our existing Services and developing new services (e.g., by conducting research to develop new products or features);
Other uses that advance our commercial or economic interests, such as communicating with you about relevant services or features provided by third party partners;
Other uses about which we notify you.
Examples of these types of uses are discussed in the “Using Your Information” section. We may also use the categories of personal information for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any particular user or device.
Sale of Personal Information
The CCPA also provides California residents with the right to opt out of the “sale” of personal information. Based on the definition of “sell” under the CCPA and under current regulatory guidance, we do not believe we engage in such activity and have not engaged in such activity in the past twelve months. We do share certain information as set forth in “Sharing Your Information” and allow third parties to collect certain information about your activity, for example through SDKs, as explained in “Information We Collect About You ” in order to provide the services that we offer. And, we provide information on a variety of ways in which you can prevent cookies and other tracking technologies from being used on your devices in the “Our Use of Analytics and Interest-Based Marketing” section.
Please note that we also do not knowingly sell the personal information of minors under 16 years of age without legally-required affirmative authorization.
California Data Access and Deletion Rights
If you are a California resident, you may have certain rights under the CCPA. California law may permit you to request us to:
Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information.
Provide access to and/or a copy of certain personal information we hold about you.
Delete certain personal information we have about you.
You may have the right to receive information about the financial incentives that we offer to you (if any). You also have the right to not be discriminated against (as provided for in applicable law) for exercising your rights. Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide our Services to you and for compliance with applicable law. If you ask us to delete certain information, you may no longer be able to access or use our Services.
California customers may request, once per year, that we disclose the identity of any third parties with whom we have shared personal information for the third parties’ direct marketing purposes within the previous calendar year, along with the type of personal information disclosed.
If would like to exercise any of these rights, please contact us at privacy@adhoclabs.co or through the webform. You will be required to verify your identity before we fulfill your request. To do so, you will need to provide your full name and email address, as well as the phone number with which you signed up for the service to confirm your account ownership with that number. You may also need to provide a receipt if you’ve made a purchase on our Services. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.
Shine the Light Disclosure
The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.
Notice to Nevada Residents
Under a Nevada law, certain Nevada consumers may opt out of the “sale” of “personally identifiable information” for monetary consideration to a person for that person to license or sell such information to additional persons, as those concepts are defined under the Nevada law, which differs from the CCPA. “Personally identifiable information” under that law includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online.
We do not engage in such activity; however, if you are a Nevada resident who has purchased or leased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by contacting privacy@adhoclabs.co. We reserve the right to take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.
Data Retention
We will retain your information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law, subject to the options available to you in “Your Choices” above. We may also maintain backups of certain data for longer than the original data for security and business continuity purposes.
Security
Ad Hoc Labs takes a variety of steps to protect the information provided via our Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet, email or other electronic transmission is ever fully secure or error free, so you should take special care in deciding what information you send to us or transmit via our services.
Other Terms and Conditions
Your access to and use of our Services is subject to the Terms of Service.
Changes to this Privacy Policy
Our Services and our business may change from time to time. As a result, at times it may be necessary for Ad Hoc Labs to make changes to this Privacy Policy. Ad Hoc Labs reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any information. This Privacy Policy was last updated on the date indicated above. Your continued use of our Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.
Contacting Ad Hoc Labs
Please feel free to contact us if you have any questions about Ad Hoc Labs’ Privacy Policy or the information practices of our Services.
You may contact us as via email at legal@adhoclabs.co, or via postal mail at Ad Hoc Labs, Attn: Privacy, 2658 Griffith Park Blvd, #134, Los Angeles, CA 90039.
