At Low Lag Labs we help mobile apps provide users with better connectivity and in-app experience on wireless networks (because nobody likes laggy internet). We work with mobile applications to improve mobile experiences that rely on connectivity and we use anonymised analytics to do so.
Wireless network performance insights that improve mobile experiences are the foundation of our business, and we adopt a privacy-first approach when we handle any data from your device.
This privacy policy will inform you how we handle data collected from your device when you opt-in to data sharing through a mobile application operated by one of our app partners.
As further detailed below, Low Lag Labs does not collect any personal information that directly identifies individuals, and our products and services do not permit or require user identification. Low Lag Labs does not sell personal data.
We collect data relating to wireless network performance to help answer questions such as:
Each App Partner (defined as a mobile application that satisfies our privacy requirements and integrates the Low Lag Labs Software Development Kit, or SDK) independently controls when the Low Lag Labs SDK is enabled to collect data. We mandate that our App Partners provide transparent disclosures to end-users, and that they only start our SDK after users opt-in. We audit our application partners regularly to ensure that these requirements are being satisfied.
As part of our privacy-first approach, our SDK does not collect advertising ID, name, email, phone number, social media ID, contact list, or anything else which directly identifies an individual or their particular device. If and where the consent and disclosure requirements are met, our SDK may collect the following types of data:
This privacy policy does not encompass or detail Low Lag Labs’s handling of internal employee or customer data. Our employees and customers may provide additional personal information such as contacts, names, email addresses, and phone numbers through the regular course of business and our non-public facing policies, which are available to those groups, govern the handling of that data.
If you contact us through lowlaglabs.com/contact or otherwise submit personal information via our website, insofar as permitted under applicable law, we may retain the information provided for our records and use it to respond to your inquiry, communicate with you in relation to our services, and/or otherwise process your request. We do not use cookies or similar tracking technologies on the Low Lag Labs website.
We collect and process the data described in this privacy policy to support the following services (“Services”):
Low Lag Labs does not sell personal data. We may share data described in this privacy policy with or in support of:
1. App Partners. We may provide analysis and datasets containing aggregated or depersonalized data to our App Partners.
2. Service Providers. We may provide datasets containing personal data to third-party service providers under private contracts to perform services on our behalf related to the Low Lag Labs Services. This includes services such as cloud storage and data processing for depersonalization. These third parties are required to manage the information exclusively for our benefit and not for their own purposes.
3. Business Transactions. In the event of a merger, acquisition, asset sale, joint venture, securities offering, bankruptcy, reorganization, liquidation, or similar transaction, or a change in ownership of our business, we may share or transfer databases containing certain data to the relevant parties involved in the transaction.
4. Legal Discolsures. To the extent permitted or required by applicable law, we may disclose information to third parties in order to:
5. Subsidiaries and Affiliates. We may share data collected from users' mobile devices with Low Lag Labs subsidiaries and affiliates to integrate complementary data on consumer experience, network performance, and subscriber behaviour.
Our Services are not intended for children under the age of 18, and we prohibit App Partners from including the Low Lag Labs SDK in applications that are targeted to children.
We implement appropriate technical and organizational measures to protect your data against unauthorized access, loss, and misuse. Data collected by our SDK is encrypted in transit.
It is important to understand that no data storage system or data transmission over the Internet or any other public network can be guaranteed to be 100 percent secure, accurate, complete, or up-to-date. Please be aware that information collected by third parties may not have the same security protections as the information you submit to us, and we are not responsible for securing such information.
The collection of data from devices takes place in the country where the device is used. We store and otherwise process data through third party cloud service providers who offer a range of global storage location options. The data we collect is shared with affiliated group entities in the United States for the purpose of the group’s data analysis and reporting purposes and an International Data Transfer Agreement, or IDTA, is in place to ensure the protection of the data when it leaves the United Kingdom, where we are based.
Any data collected by the Low Lag Labs SDK is retained only as long as necessary to fulfil the purposes for which it was collected. This includes meeting any legal, accounting, or reporting obligations. We may keep data for a longer period if there is an ongoing complaint or if we reasonably foresee potential litigation regarding our relationship with an end user.
When determining the appropriate retention period for data, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the data and whether those purposes can be achieved by other means, and the relevant legal requirements.
We gather and handle data with your explicit consent. You have the option to withdraw this consent at any time using the features available within the App Partner’s mobile application, such as the personal settings menu. This withdrawal will not impact the legality of any data processing conducted prior to the withdrawal of consent. Additionally, for data collected with your permission, we base our actions on our legitimate interests in operating our business, performing statistical and scientific research, providing analytical insights to our clients, and enhancing global connectivity for users like you.
Your personal data will be utilized solely for the purposes it was collected. Should there be a need to use your data for a different purpose, we will ensure that it is compatible with the original intent. If you require clarification on how a new purpose aligns with the original one, please reach out to us.
Data subjects may have the following legal rights depending on applicable law in respect of their personal data that we process:
The right to require Low Lag Labs to confirm whether or not your information is being processed, the purpose of any such processing, the recipients of any information that has been disclosed, the period for which your information is to be stored and whether any automated decision-making processes are used in relation to your information;
The right to require access to the personal data and to require Low Lag Labs to rectify inaccurate information;
Where Low Lag Labs has relied on the ‘consent’ basis for processing that information, the right to withdraw your consent at any time. This right to withdraw consent does not affect the lawfulness of processing based on consent before its withdrawal;
The right to request the erasure of their information. You can make a request for erasure where:
the information is no longer necessary in relation to the purpose for which it was collected;
where the processing of the information is based on your consent (and the other circumstances described in the ‘Legal Basis for Processing Your Data’ and ‘How We Share Personal Information’ sections above no longer apply), if you withdraw your consent; or
where the personal data is processed by Low Lag Labs solely on the basis of our ‘legitimate interest’, if you withdraw your consent for the processing of your data and you object to the processing of your personal data and there are no overriding legitimate grounds for the processing (such as, for example, the achievement of the purpose of using your data for statistical or scientific research purposes or where the processing of the data is required to meet statutory obligations or for the defense of legal claims).
Where Low Lag Labs has disclosed your information of a data subject to a third party and you request the erasure or rectification of the data, Low Lag Labs will take any steps required under relevant laws to inform the third party of such request.
The right to require Low Lag Labs to restrict its processing of your personal data in certain circumstances, such as where the accuracy of that data is disputed or an objection has been raised. In such circumstances, Low Lag Labs will only process that information with your express consent, or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest;
Where data is processed based on your consent or to fulfill a contractual obligation provided for by law, you have the right to receive your personal data from Low Lag Labs in a structured, commonly used and machine-readable format;
The right to object to the processing of personal data where:
a.Low Lag Labs relies solely on the ‘legitimate interest’ basis for processing that data, in which case we will be legally required to stop processing your information unless we have compelling legitimate grounds for the processing which override your privacy rights and interests; or
b.the information is used for direct marketing purposes, in which case we will immediately stop processing your information for such purposes.
You have the right to lodge a complaint with the UK’s Information Commissioner’s Office (www.ico.org.uk) or in some cases with the data protection supervisory authority or regulator of the jurisdiction where you reside. We would, however, appreciate the chance to deal with your concerns before you approach the authority or regulator, so please contact us in the first instance.
You have the right to ask that we transfer the personal information you gave us to another organization, or to you, in certain circumstances.
The above legal rights are subject to various conditions and exceptions including where the data is used for statistical or scientific research purposes and the exercise of the right would prevent such purposes from being attained or would seriously impair their attainment. In addition, there are, consistent with relevant laws, limitations on our ability to honor requests to exercise these rights for data that cannot be linked to a verified request, such as where data has been de-personalized.
To exercise these rights, please call us at (+44) 020 3290 8047 or email us at privacy@lowlaglabs.com. You may be entitled, in accordance with applicable law, to appeal a refusal to take action on your request; to do so, please see any applicable instructions in our response to your request. We will aim to respond to any request within one month. Please note that we cannot fulfill requests to know the specific pieces of personal information that we may have collected about you. In order to disclose the specific pieces of personal information that we may have collected about you, we would have to verify your identity to a reasonably high degree of certainty. Given the limited amount of information that we collect about you, we do not maintain enough data points to verify your identity to the reasonably high degree of certainty required by relevant law.
Our data processing activities do not include the sale of personal data, the use of personal data for targeting advertising, or the use of personal data for profiling in furtherance of decisions that produce legal or similarly significant effects, although we may disclose aggregated or depersonalized data with external sources, as described above. As a result, we do not honor rights to opt out of these practices in jurisdictions that recognize such rights.
You can also authorize another person, called an agent, to exercise your rights on your behalf. You must provide the authorized agent written and signed permission to act on your behalf. We may deny requests from an authorized agent who does not submit proof that he or she has been authorized to act on your behalf. Furthermore, we may require you to verify your identity directly with us. We may also require you to directly confirm with us that you have provided the authorized agent permission to submit a request on your behalf. An authorized agent can make a request on your behalf by either calling us at (+44) 020 3290 8047 or by emailing us at privacy@lowlaglabs.com.
We may not discriminate against you because you exercised any of your data subject rights, although some of the functionality and features available on the service may change or no longer be available to you. Any differences in the services are related to the value provided.
You will not need to create an account to exercise your rights. California residents have the right to:
Delete. To exercise this right, you must provide a verifiable consumer request by either calling us at (+44) 020 3290 8047 or by emailing us at privacy@lowlaglabs.com.
Know. You may request that, for personal information we disclose, we provide you the categories of personal information that we have collected about you, the categories of sources from which the personal information was collected, the business or commercial purpose for collecting personal information, if applicable, the categories of third parties with whom we share personal information. To exercise this right, you must provide a verifiable consumer request by either calling us at (+44) 020 3290 8047 or by emailing us at privacy@lowlaglabs.com.
Access. You may request that, for personal information we disclose, the categories of personal information that we have collected about you, the categories of personal information that we have disclosed about you for a business purpose, and the categories of third parties to whom each category of personal information was disclosed. To exercise this right, you must provide a verifiable consumer request by either calling us at (+44) 020 3290 8047, or by emailing us at privacy@lowlaglabs.com.
Opt out of sale. We do not sell your personal information within the meaning of the California Consumer Privacy Act of 2018 (“CCPA”). Under the CCPA, “sell” means sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate orally, in writing, or by electronic or other means a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration. The law contains exceptions to this definition which may limit how we respond to a request by you. To exercise this right to opt out, you may call us at (+44) 020 3290 8047 or email us at privacy@lowlaglabs.com. We do not have actual knowledge that we sell the personal information of minors under 18 years of age, and minors under the age of 18 may not use the Low Lag Labs Services.
In addition, there are, consistent with relevant laws, limitations on our ability to honor requests to exercise these rights for data that cannot be linked to a verified request, such as where data has been depersonalized, or whether there are other relevant exceptions under California law.
We do not provide a right to limit our use of sensitive personal information, because in the event that we collect certain sensitive personal information, we do not use it to infer characteristics such that we would be required to provide a right to limit.
To the extent that anything in this Section conflicts with this Privacy Policy, this Section shall govern.
The categories of California consumers’ personal data we may have collected are listed above in the Section – DATA COLLECTION. We may disclose the following categories of data to our customers, although personal information is aggregated or depersonalized before it is shared: (1) Location, (2) Identifiers such as IP address, and (3) Internet or other electronic network activity information, all of which we have collected from your mobile device. We may collect the categories we’ve previously identified (which include GPS coordinates or similar information), network type, network operator, cellular and Wifi signal strength and quality, and the identifiers of connected cell towers and Wifi routers (including both BSSID and SSID). We also measure how data is flowing, both passively (by monitoring how fast it moves through other mobile applications), and actively (by running a test that downloads or uploads data within our SDK). We do not monitor the content of your data usage. The goal of collecting the above data is to measure the experience you have of wireless networks. We also collect information from environmental sensors on your device (depending on which ones are integrated in your device), this allows us to measure things such as the device acceleration, orientation and the external atmospheric pressure and light intensity. We also measure some internal device conditions – such as battery temperature and voltage. The goal of collecting this data is to understand how instantaneous device conditions affect the experience of wireless networks.
To better understand differences between devices, we collect data on your device hardware such as the model, manufacturer, and manufacturers and models of sub-components (such as the cellular radio) and the capabilities of these components (for example the number of cores on the CPU). Similarly, to understand differences caused by software, we collect information on the mobile platform version used and whether custom ROMs or Android skins are installed. The goal of collecting this data is to understand how device properties affect the experience of wireless networks.
When you first use a mobile application an identification code (“Resettable ID”), is randomly generated by our software and allocated to that installation instance rather than the device whenever we take measurements. A different and unique Resettable ID will be generated by each mobile application on a particular device. New installations of the same mobile application will also generate new unique Resettable IDs. Resettable IDs are random, unrelated to each other, specific to Low Lag Labs, and not shared externally. To further help us manage the data, we also collect IP addresses, as these may indicate which telecom carrier network is being accessed and is impacting your experience.
We use this data for the purposes listed above in the Section – DATA COLLECTION - Typical Uses. Measurements that we take from the mobile devices of individual network users allow us to create a detailed picture of the service availability, quality and performance of numerous communication networks across the world and over time.
Shine the Light Notice
Section 1798.83 of the California Civil Code permits California residents to request from a business, with whom the California resident has an established business relationship, certain information about the types of personal information the business has shared with third parties for those third parties’ direct marketing purposes, and the names and addresses of the third parties with whom the business has shared such information during the immediately preceding calendar year. You may make one request each year by emailing us at privacy@lowlaglabs.com with "Request for California Privacy information" in the subject line, or by writing us at the address listed at the end of this Policy.
Your Nevada Privacy Rights Senate Bill No. 220 (May 29, 2019) amends Chapter 603A of the Nevada Revised Statutes to permit a Nevada consumer to direct an operator of an internet website or online service to refrain from making any sale of any covered information the operator has collected or will collect about that consumer. You may submit a request pursuant to this directive by emailing us at privacy@lowlaglabs.com. We will provide further information about how we verify the authenticity of the request and your identity.
Your Rights Under the Virginia Consumer Data Protection Act
If you are a resident of Virginia, you have certain rights regarding your personal data under the Virginia Consumer Data Protection Act (VCDPA). This notice applies to natural persons who are residents of Virginia acting only in an individual or household context. It does not apply to natural persons acting in a commercial or employment context. To exercise any of these rights, please contact us at privacy@lowlaglabs.com. We will provide further information about how we verify the authenticity of the request and your identity.
Your Rights Under the Lei Geral de Proteção de Dados (Brazil)
If you are a resident of Brazil, you have certain rights regarding your personal data under the Lei Geral de Proteção de Dados (LGPD). This notice includes information such as our purposes of personal data processing, the rights you have regarding our processing of your personal data, and how to contact us if you have any questions or requests regarding our processing of your personal data. To exercise any of these rights, please contact us at privacy@lowlaglabs.com. We will provide further information about how we verify the authenticity of the request and your identity.
We may share aggregated or depersonalized data relating to users of the Low Lag Labs Services with affiliated or unaffiliated third parties for any purpose.
If you have any questions about this privacy policy or our data practices, or want to exercise your privacy rights, please contact us at:
Low Lag Labs Privacy Team & Data Protection Officer
c/o The Boutique Workplace Company, 6 Bennetts Hill, Birmingham B2 5ST
Email: privacy@lowlaglabs.com
In compliance with Article 27 of GDPR, Low Lag Labs has designated Ametros Group Ltd as EU Local Representative:
Ametros Limited
Unit 3D - North Point House - North Point Business Park
New Mallow Road
Cork – Ireland
We will notify you of changes by posting the modified version on our website. We will indicate the date it was last modified below.
Last updated: September 5, 2024