This Neer Privacy Policy describes our policies and procedures on the collection, use and disclosure of your information on www.neerlife.com (the “Website”) and through our mobile location sharing service that enables, among other things, users to automatically share when they enter or leave designated places (“Neer” or “Neer Services”). When visiting our Website or using any of our Neer Services you agree to this Privacy Policy. The Website and the Neer Services are provided by Qualcomm Services Labs, Inc., a company headquartered and incorporated in California (“we”, “us”, and “our”).

1. Data we collect

We collect your personal information in the following ways:

a. Your Location

Neer is a location based service. To determine where you are, we’ll collect the latitude/longitude coordinates from your mobile device and whether those coordinates come from GPS satellites or your mobile network. Alternatively, we may determine where you are by detecting the wireless access points around you that we have associated with the places you establish in the Neer Services. From wireless access points, we may collect general information such as: SSIDs, BSSIDs, information about the signal strength and frequency, and, if your device is connected to a wireless access point, the mac address. We will not collect, however, any content sent over wireless access points or “payload” data.

b. Registration

In order to use our Neer Services, you must provide us the following information to create an account: your first and last name, your email address, mobile phone number, and a password you create. Like other passwords, you should choose one that is known only by you. We will also collect your birth date to determine if you are of legally sufficient age to use the Neer Services.

c. Set-Up & Use of the Neer Services

After registering, you will be directed through the set-up process where we will collect information from your phone’s address book (such as email addresses, phone numbers, and any associated pictures) and your call and text logs in order to enable you to easily set up groups of people with whom you may choose to share information (creating “groups”). We will suggest people from this information to include in a group and you may accept or reject our suggestions. We will also compare the people in your phone’s address book with our existing Neer users to enable you to invite non-registered users to use the Neer Services. After set-up, we will periodically check for changes in your phone’s address book to ensure those changes are reflected in the Neer Services.

During set-up, you can also designate physical places about which you want to share when you enter or exit those places. You can designate places such as “work” or “home” (“places”) and the times (if any) at which you wish to automatically share with your designated groups when you have arrived at, or departed from, those places. To provide these features, we’ll collect certain information about the places you set-up such as: geolocation information (e.g., GPS coordinates), general information about wireless access points, and the name you associate with that place. From wireless access points, we may collect general information such as: SSIDs, BSSIDs, information about the signal strength and frequency, and, if your device is connected to a wireless access point, the mac address. We will not collect, however, any information about the content sent over wireless access points or “payload” data.

After you have set-up the Neer service, we will periodically collect your location to determine whether you have entered or left the general area of one of your predetermined places and we will share that information with the groups of people you have indicated. This data collection will be performed in the background either by accessing the GPS information from your device, or by detecting a nearby wireless access point that we have associated with one of your places. The Neer Services may also allow you to send status updates and other messages to your contacts or other users and those messages will be stored on our servers.

d. Third Party Services

To show your location on a map, we’ll request a map from Google of your latitude/longitude coordinates. We will not, however, share with Google your name or any other identifying information.

e. Our Website

Due to the communications standards on the internet, when you visit the Website we automatically receive the URL of the site from which you came and the site to which you are going when you leave Neer. Neer also receives the internet protocol (“IP”) address of your computer (or the proxy server you use to access the World Wide Web), your computer operating system and type of web browser you are using, email patterns, mobile device operating system (if you are accessing Neer using a mobile device), as well as the name of your ISP or your mobile carrier. We use this information to analyze overall trends to help improve the service. The linkage between your IP address and your personally identifiable information is not shared with third parties without your permission, except as described in this Privacy Policy.

f. General Usage Information Collected

We’ll collect information about how you use our Website and Neer Services such as: (i) the services that you access, (ii) information about the links and/or advertisements that you click, (iii) your interaction with third party platforms (e.g., your phone dialer or SMS client), (iv) the frequency and duration of use, and (v) the fact that you use certain features or functions. We will use this information in order to provide and improve our Website and Neer Services and to help maintain your groups.

g. Cookies

If you visit our Website, we may place a small data file on your computer (called a “cookie”) when you login to identify you as you navigate around our Website and to enhance and personalize your experience. In addition we may use cookies to help us display relevant advertising or recommendations to you when you visit our Website. These cookies also help us measure the performance of our advertising campaigns. You are free to decline cookies, but by doing so, you may not be able to use certain features on the Website or take full advantage of all of our offerings. Check the “Help” menu of your browser to learn how to change your cookie preferences.

h. Information You Submit

If you voluntarily submit information to us – for example, if you participate in a survey, provide us feedback, or respond to our request for information – we will collect the information you submit. In each such instance, you will know what data we collect, because you actively submit it. We will use the data you voluntarily submit to us for the purposes we describe in this Privacy Policy, as well as any purposes that we describe to you when we collect such information.

2. Cross-Border Transfer

The information we collect is stored and processed on servers in the United States and may also be stored in other locations around the world. By using the Neer Services you consent to the transfer of the information described in this Privacy Policy to locations that may be outside of the country in which you live, and such places may be in the United States, within one or more European countries, and/or in one or more countries within Asia. If you choose to access the Neer Services from outside the United States, you do so on your own initiative and are responsible for compliance with local laws. If any provision within this Privacy Policy is held to be invalid or unenforceable, such provision shall be struck and all remaining provisions shall be enforced.

3. Uses of Personal Information

In addition to the other uses of your information described in this Privacy Policy, we may use and process the data we collect for the following general purposes:

a. To provide, protect, and improve our Neer Services, Website and our systems, including providing customized recommendations, content, and advertisements;

b. To respond to requests that you may send us such as your request for information, or your request to subscribe to a service we offer;

c. To develop new products and services, and other internal business purposes;

d. To protect our rights and the rights of our users;

e. To inform you about our products and services as well as third-party products and services in which we think you may be interested; and

f. Any other use we describe at the point where we collect the data.

To the extent permitted by applicable law, we reserve the right to combine the various types of data that we collect and to combine the data that we collect with anonymous or aggregated data (e.g., demographic information) that we obtain from third parties or other sources. We may use the combined data for any of the purposes described in this Privacy Policy.

4. Data Sharing

a. Aggregated/Anonymous Data. We may share anonymous and/or aggregated data that does not personally identify you with our customers and business partners (and prospective customers and business partners), other third parties, the press, and the public for any of the purposes indicated in this Privacy Policy, including in the “Uses of Personal Information” section. For example, we may share anonymous and/or aggregated data with our business partners or affiliates to provide you more personalized recommendations and to make the advertisements you ordinarily see on our Website or through the Neer Services more relevant to you. While we do not share your personally identifiable information with business partners or affiliates unless you have granted us permission, our business partners or affiliates may use cookies or web beacons in association with their ads or recommendations which note that you have met their targeting criteria. We may also share non-personally identifying, aggregated data such information as the number of our subscribers visiting a place or business, or the frequency of use of the Neer Services.

b. Personally Identifiable Information. We do not share your personally identifiable information with others, except as follows: We may share your information with agents, service providers, vendors, contractors, or affiliates who process the data only on our behalf for the purposes set forth in this Policy and under terms of confidentiality. We may also share your information as required by law or in the interest of protecting or exercising our or others’ legal rights, e.g., without limitation, in connection with requests from law enforcement officials and in connection with court proceedings. We may share or transfer your information in connection with a prospective or actual sale, merger, transfer or other reorganization of all or parts of our business. Finally, we may also share your personal information where you have granted us permission.

c. Other Disclosures to Third-Parties. Other than as set forth above, and what you chose to share using Neer Services, we do not otherwise share information with third-parties unless you have specifically given us permission.

5. Forums and Blogs

Our Website may provide a forum, blog, or other interactive feature that allows you to disclose information directly to other users. Your participation in such interactive features is completely voluntary and we assume no obligations or responsibility with respect to the information you provide or share through such interactive features. To participate in these interactive features, we may require you to register with us and provide certain information such as your name, email address, location, phone number, and desired display name (which may be viewable by other users of the interactive features). We or our service providers acting on our behalf may use the information you provide during the registration process for analytical and development purposes (such as to make product or service enhancements) and to enable you to use the interactive features and to manage your account. You may also personalize our interactive features by voluntarily providing additional information such as your location, instant message contact information, website address, occupation, and other information. Our interactive features may also allow you to upload an avatar or other graphical representation of yourself. If you voluntarily provide such additional information, it may be viewable by other users of the interactive features – so you should not provide information you do not want other users to see.

6. Links

The site may contain links to third party websites with which we do not own or control. Except as set forth herein, we do not share your personal information with those third parties, and are not responsible for their privacy practices. We suggest you read the privacy policies on all such third party websites.

7. Opt Out

If you do not want us to collect, use, and share the information we describe in this Policy, please discontinue your use of the Website and Neer Services and uninstall all of our software from your computer or device. To close your account and delete the information we have about you, please see the Section “Closing Your Account & Deleting Information”, below.

In connection with promotions, surveys, or other projects, we may ask you whether you object to our specified data use or sharing. If you opt-out under such circumstances, we will respect your decision. Please note that our affiliates and other data recipients have their own data privacy policies, which may differ from ours and you would have to contact them separately with respect to opt-out requests.

8. Accessing and Changing Your Account Information

You can review the personal information you provided to us and make any desired changes to the information you share, or to the settings for your Neer account at any time by logging in to your account. Please be aware that even after your request for a change is processed, Neer may, for a time, retain uncorrected, residual information about you in its backup and/or archival copies of its database. If you would like to access other personal information we may have associated with your account, please contact us using the Contact Us form on the Website or through the Contact Us section below. Upon appropriate request we will provide you a copy and/or description of any personal information we hold about you within in a reasonable time and we will correct or delete it upon your request. For information about deleting your data, see the Section “Closing Your Account & Deleting Information”, below.

9. Closing Your Account & Deleting Information

You can close your account by accessing the “How to Neer” section of the Neer Services or Website, or by contacting us as set forth in the “Contact Us” section below. If you close your Neer account, we will remove the information we have about you from our publicly viewable database within a reasonable time but we may retain information about you in our non-public databases for a reasonable period of time to support our operational requirements (for example only, reconciling your transactions). Notwithstanding the foregoing, there may be circumstances where we are legally required to retain the information we collect about you (for example, in connection with court proceedings) and despite your request for us to delete your information, we will retain what we are legally required to keep. Moreover, we reserve the right to make anonymous the information so that it is no longer associated with you rather than deleting it. We also reserve the right to use previously obtained information to verify your identity or take other actions that we believe are appropriate. If you close your account, we have no obligation to retain your information, and may delete any or all of your account information without liability.

10. Children

The site is intended for general audiences and is not directed to children under 13. We do not knowingly collect personal information from children under 13. If you become aware that your child has provided us with personal information without your consent, please contact us as set forth in the section “Contact Us” below. If we become aware that a child under 13 has provided us with personal information without parental consent, we take steps to remove such information and terminate the child’s account.

11. Changes to this Privacy Policy

We may change this Privacy Policy from time to time and in our sole discretion. If we materially change this Privacy Policy with respect to your personal information, we will provide appropriate notice to you either on the Website or through the Neer Services and give you a choice with respect to the change. When we make changes to this Privacy Policy, we will alert you that changes have been made by indicating on the Privacy Policy the date it was last updated. When you visit the Website or use the Neer Services, you are accepting the current version of this Privacy Policy as posted on the Website and through the Neer Services at that time. We recommend that users revisit this Privacy Policy on occasion to learn of any changes.

12. Security

We take reasonable steps to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. It is your responsibility to protect the security of your login information.

13. Contact Us

Please feel free to contact us with any comments, questions or suggestions you might have regarding the information practices described in this statement. You may contact us using the Contact Us within the Website or write to us at:

Qualcomm Services Labs, Inc.
5775 Morehouse Drive
Attn: Privacy Compliance Officer
San Diego, California
92121

Neer and the Neer logo are trademarks of Qualcomm Services Labs, Inc. All other marks are owned by their respective owners.

Effective: July 23, 2010