Location Engine Privacy Policy

Effective Date: 10/26/2020

Airport Engine, Inc.  and our subsidiaries and affiliates (collectively, “Location Engine,” “we,” “us,” or “our”) respect your concerns about privacy and value our relationship with you.  We are committed to transparency about the data we collect from or about you.  This Privacy Policy (“Privacy Policy”) describes how we collect, use, and share your personal information in connection with the website located at http://locationengine.com and any other websites operated by Location Engine that link to this Privacy Policy (each, a “Site”) and the Location Engine virtual assistant and related products and services (together with the Sites, the “Service”), and the rights and choices available to individuals with respect to their information.

Location Engine reserves the right, at any time, to modify this Privacy Policy.  If we make revisions that change the way we collect, use, or share personal information, we will post those changes in this Privacy Policy.  You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices.  We will note the effective date of the latest version of our Privacy Policy above.  We may also provide notification of changes in another manner that we believe is reasonably likely to reach you, such as via email or another manner through the Service.  In all cases, your continued use of the Service following posting of changes constitutes your acceptance of such changes.

Location Engine is committed to providing users of our Service with the best experience possible while endeavoring to minimize the amount of personal information we collect from you.  This is a core value of our business and a mission we align our business practices to.



Personal Information We Collect. 
The following are categories (with non-exhaustive examples) of personal information we may collect about you:



A.  Individual Identifiers and Demographic Information

Contact details, such as your phone number or email address.

Identifiers, such as your IP address, device ID, and other online identifiers (including identifiers set by Service partners).

Demographic data, such as general location information like city, state or geographic area.

B.  Geolocation Data

Your geolocation, including your precise physical location or movements, when you authorize Location Engine to collect such information.

C.  Commercial Information 

Service communications, such as the directions and services you request and your conversations with our virtual assistant.

Survey responses, such as information that you provide when you participate in one of our surveys.

Marketing data, such as your preferences for receiving communications from our virtual assistant and details about how you engage with our communications.

D.  Professional or Employment-Related Information

Professional data, such as your profession, household income, and other employment-related information.

E.  Education Information

Education background, such as the number of years of school you have completed or field of study.  

F.  Internet or Network Activity

Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, and the website you visited before browsing to our website.

Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.

G.  Inferences Drawn from Personal Information

Profiles reflecting your preferences, usage, and characteristics, such as inferences regarding your preferences when using the Service and other characteristics about your interaction with the Service that we may combine with other personal information we collect about you as described in this table.

Other Personal Information.  
We may also collect other personal information that is not specifically listed in the table above, including any information that you choose to provide when you communicate with us or our virtual assistant.  We will use all such personal information as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Deidentified or Aggregate Information.
We may also collect or create Deidentified Information or Aggregate Information about you.  “Deidentified Information” is information that cannot reasonably identify or be linked to you.  We implement technical safeguards and business processes to prohibit the reidentification of such data.  “Aggregate Information” means information that relates to a group or category of individuals, but your individual identity has been removed so that it cannot be reasonably linked to you.


We obtain the personal information described above from the following categories of sources:

Personal Information You Provide.  
We collect personal information when you voluntarily submit it to us.  For example, we may collect or receive personal information when you sign up to use the Service, communicate with our virtual assistant, respond to a Location Engine survey, contact our customer service team, or otherwise interact with us.

Personal Information Collected Automatically.  
We, our service providers, and our business partners may automatically log information about you, your computer or mobile device and your activity over time on our Service and other sites and online services, such as your identifiers, precise geolocation (when you authorize us to collect you location data via your mobile device), device data, and online activity data.  Like many online services, the Service may use the following technologies to facilitate our automatic data collection:

Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.

Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.

Personal Information Obtained from Third Parties.  
We may receive personal information about you from our Service partners or sponsors, data providers, and other business partners and third parties.  For example, when you sign up for the Service, we may receive information about your upcoming travel and transit plans to provide you with directions, alerts, and location guidance.  If you connect to the Service using a social media network, third party messaging platform, or other third party service, or otherwise use or connect to a third party service through the Service, the third party service may also provide us with your personal information.  We may merge or combine such personal information obtained from third parties with the personal information we collect from you directly or automatically.
Personal Information About Others.  

Users of the Service may have the opportunity to refer friends and other contacts to us and share their contact information with us.  Please do not refer someone to us or share their contact information with us unless you have their permission to do so.


We may use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

To Provide Our Products and Services.  
We may use your personal information to:
  • provide you with the content, features, products and services that you request;
  • respond to your questions, requests, and conversations with our virtual assistant;
  • communicate with you about the Service (including by sending announcements, updates, security alerts, and support and administrative messages);
  • understand your interests, personalize your experience on the Service, and deliver information about products and services relevant to your interests; and
  • respond to your inquiries and requests for customer support, including to investigate and address your concerns and monitor and improve our responses.
For Research and Development. 
We may use your personal information for research and development purposes, including to analyze and improve the Service and our business.  For example, we (or our service providers) store and process copies of user conversations with our virtual assistant.  Personnel may review these transcripts for accuracy and to further analyze and improve how the virtual assistant functions.

To Create Anonymous Data.  
We may create Deidentified Information or Aggregate Information from the personal information you provide.  We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

For Marketing and Advertising.  
We and our business partners may collect and use your personal information for direct marketing and interest-based advertising purposes.

Direct Marketing.  
We may send you Location Engine-related or other direct marketing communications as permitted by law.  You may opt-out of our marketing communications as described in the “Opt-Out of Marketing Communications” section below.
Interest-Based Advertising.
We also contract with third-party advertising companies and social media companies to display ads on our Service and other sites and services.  These companies may use cookies and similar technologies to collect information about you (including the device data and online activity data described above) over time across our Service and other sites and services or your interaction with our emails, and use that information to serve ads that they think will interest you.  You can learn more about your choices for limiting interest-based advertising, in the “Advertising Choices” section below.

Compliance and Protection.  
We may use your personal information to:
  • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
  • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
  • audit our internal processes for compliance with legal and contractual requirements and internal policies;
  • enforce the terms and conditions that govern the Service; and
  • prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.


We may share your personal information with the following third parties and as otherwise described in this Privacy Policy or at the time of collection: 

Business Partners.  
Our Service partners or sponsors and other business partners and third parties, such as those that have joined our programs or jointly offer content, promotions and other service offerings with us.  If you choose to use or connect a third party service through the Service, we may need to share your personal information to facilitate the connection.  Please note, we do not control the third party’s use of your personal information and you should review the privacy policy of the entities that provide these platforms.

Related Companies.
Our subsidiaries and affiliates, for purposes consistent with this Privacy Policy.

Business Transferees.
If we sell all or part of its business or make a sale or transfer of assets or are otherwise involved in a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Location Engine or our affiliates (including, in connection with a bankruptcy or similar proceedings), we may transfer your personal information to a third party as part of that transaction, including at the negotiation stage.

Authorities and Others.  
Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate to comply with law or for the compliance, fraud prevention and safety purposes described above.
Service Providers.  
Companies and individuals that perform services on our behalf that provide services on our behalf or help us operate the Service or our business.  Among other things service providers may help us perform website hosting, maintenance services, database management, web analytics, billing, payment processing, fraud protection, or marketing.  For example, we work with Google Maps to display real-time location and directions data.  To provide these services, Google will collect your personal information and use it in accordance with Google’s privacy policy, available here.

Advertising Partners.  
Third party advertising companies that collect information about your activity on the Service and other online services to help us advertise our services, and/or use hashed customer lists that we share with them to deliver ads to them and similar users on their platforms.

Professional Advisors.  
Our professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.


You can make the following choices with respect to your personal information.
Opt-Out of Marketing Communications.
If you receive marketing text messages from us, you may opt out of receiving further marketing text messages from us by replying STOP to our marketing message.  You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at privacy@locationengine.com.  You may continue to receive service-related and other non-marketing emails.

Third Party Services. 
If you choose to use or connect to the Service through a social media network, third party messaging platform, or other third party service, you may be able to use your settings in your account with that service to limit the information we receive from it.  If you revoke our ability to access information from a third party service, that choice will not apply to information that we have already received from that third party.  You may also be able to control your privacy settings with any third party services that you use through the Service, such as Google Maps, by changing your settings on the applicable service.


Most browsers let you remove and/or stop accepting cookies from the websites you visit.  To do this, follow the instructions in your browser’s settings.  Many browsers accept cookies by default until you change your settings.  If you do not accept cookies, however, you may not be able to use all functionality of the Service and our Site may not work properly.  For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.

We use Google Analytics to help us understand user activity and patterns on the Site.  You can learn more about Google Analytics cookies by clicking here and about how Google protects your data by clicking here.  You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing a browser plugin available here.

Advertising Choices. 
Some of our advertising partners are members of the Network Advertising Initiative (NAI) and are subject to the Self-Regulatory Principles for Online Behavioral Advertising published by the Digital Advertising Alliance (DAA).  You can obtain more information about these companies’ information collection practices, and opt-out of receiving interest-based advertising from participating NAI and DAA members at http://www.networkadvertising.org/managing/opt_out.asp and/or the DAA’s website at optout.aboutads.info.  Mobile app users may opt out of receiving interest-based advertising in mobile apps provided by participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available at https://www.youradchoices.com/appchoices.  You can also limit collection of your information for interest-based ads by blocking third party cookies in your browser settings or using privacy plug-ins or ad blocking software that help you block third party cookies.  In addition, your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for targeted online advertising purposes.  If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.
Some of the third party advertising companies we work with offer their own opt-out options that you can use to limit their use of your information for interest-based advertising, including as Google (info and opt-out) and Facebook (info and opt-out).  Please note that we also may work with companies that offer their own opt-out mechanisms or do not participate in the opt-out mechanisms described above.  Even after using these opt-out mechanisms, you may receive interest-based advertising from other companies.
Do Not Track.  

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals.  To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to Provide Information.  
We need to collect personal information to provide certain services.  If you do not provide the information requested, we may not be able to provide those services.


The security of your personal information is important to us, and we strive to put protections and safeguards in place to protect your data.  However, no method of transmission over the Internet, or method of electronic storage, is fully secure.  While we use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal information.


The Service may contain links to other websites and online services operated by third parties.  These links are not an endorsement of, or representation that we are affiliated with, any third party.  In addition, our content may be included on web pages or online services that are not associated with us.  We do not control third party websites or online services, and we are not responsible for their actions.  Other websites and services follow different rules regarding the collection, use and sharing of your personal information.  We encourage you to read the privacy policies of the other websites and online services you use. You can access the Privacy Policy for our partner Grab (food ordering) by clicking here. The Privacy Policy for our mapping provider Locus Labs can be found here


Location Engine is based in the United States of America.  If you are from a country outside of the United States of America with laws governing data collection, use, and disclosure that may differ from U.S. law and you provide personal information to us, please note that any personal information that you provide to us may be transferred to the United States of America.  By providing your personal information, where applicable law permits, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein or in any applicable terms of service.


The following applies to residents of California.
Notice to California Residents.  
Location Engine must disclose whether the following categories of personal information are disclosed for a “business purpose” or “valuable consideration” as those terms are defined under California law.  Note that while a category below may be marked, that does not necessarily mean that we have personal information in that category about you.  In the preceding twelve months, we have disclosed the following categories of personal information in the manner described.


Personal Information is Disclosed for a Business Purpose

Personal Information is Disclosed for Valuable Consideration

A.  Individual Identifiers and Demographic Information



B.  Geolocation Data



C.  Commercial Information



D.  Professional or Employment-Related Information



E.  Education Information



F.  Internet or Network Activity



G.  Inferences Drawn from Personal Information



Your California Privacy Rights. 
As a California resident, you have the rights listed below.  However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
  • Access to Your Personal Information.  You may request access to your personal information by contacting us as described below.  We will grant you reasonable access to the data that we have about you as required by law.
  • Deletion of Your Personal Information.  Typically, we retain your personal 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.  You may, however, request that we delete your personal information by contacting us as described below.  We will grant a request to delete information as required by law, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.  Except as provided above, we will delete, aggregate, or de-identify all of your personal information as described in this subsection within the timeframes required by law.
  • Opt-Out of Sales.  If we sell your personal information, you can opt-out.  In addition, if you direct us not to sell your personal information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.
Exercising Your California Privacy Rights.  
When exercising the rights or options described in this section, the following guidelines apply:
  • No Fee Usually Required.  You will not have to pay a fee to access your personal information (or to exercise any of the other rights).  However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.
  • What We May Need from You.  When exercising your rights or otherwise assisting you, we may need to request specific information from you to help us confirm your identity.  This is a security measure to ensure we do not disclose personal information to any person who is not entitled to receive it.  We may also contact you to ask you for further information in relation to your request to speed up our response.
  • Time to Respond.  We try to respond to all legitimate requests within 30 days of your request.  Occasionally it may take us longer than 30 days to respond, for instance if your request is particularly complex or you have made a number of requests.  In this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.
  • No Discrimination.  You will not be subject to discrimination as a result of exercising the rights described herein.  In some cases, when you exercise one of your rights, we will be unable to comply with the request due to legal obligations or otherwise, or we will be unable to provide you certain products or services.  These responses are not discrimination and our reasons for declining your request or ceasing services will be provided at that time.
  • Authorized Agent.  You may designate an authorized agent to make a request on your behalf.  In order to designate an authorized agent to make a request on your behalf, you must provide the requester’s proof of identification and the authorized agent’s proof of identification.
You may request to exercise your California privacy rights to access or deletion by emailing us or writing to us as described in the “CONTACTING US” section below.
You may request to exercise your right to opt-out of the “sale” of personal information by visiting the Do Not Sell My Personal Information section of our the website or emailing us as described in the “CONTACTING US” section below.


If you have any questions or concerns about our Privacy Policy or any other privacy or security issue, please contact us at:

Airport Engine, Inc.
Attn: Location Engine Privacy Agent
80 Nassau Street, Suite 601
New York, NY 10038

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