Geolocation data providers (Michigan Department of Attorney General)

To Whom It May Concern:

The Electronic Frontier Foundation (EFF) seeks records describing the relationship between your agency and third-party providers of geolocation data. In particular, we seek records related to:
• the location data provider Gravy Analytics and its subsidiary Venntel
• Babel Street’s service Locate X.

For the purposes of this request, the term “geolocation data” refers to GPS data acquired from cell phone apps, connected vehicles, or other connected devices, or from third-party aggregators of such data, which pertains to the location of individual persons or devices, whether identified or de-identified.

We request the following records for the period between January 1, 2015 and the present:

- All contracts or written agreements between Michigan Department of Attorney General, or consultants thereof, and Gravy Analytics, Venntel, or Babel Street;
- All presentations, marketing materials, or proposals by contractors, subcontractors, or consultants working with Michigan Department of Attorney General relating to the use of geolocation data from Gravy Analytics, Venntel, or Babel Street;
- All technical documentation, guides, presentations, or policies describing access to, storage of, or use of geolocation data acquired from Gravy Analytics, Venntel, or Babel Street;
- All privacy policies, memoranda of understanding, data-sharing agreements, or terms of use applying to geolocation data acquired from Gravy Analytics, Venntel, or Babel Street;
- All written communications, emails, and attachments between Michigan Department of Attorney General and Gravy Analytics, Venntel, or Babel Street;
- All written communications, emails, and attachments between Michigan Department of Attorney General and INRIX.

If your office or agency contracts with a company not named here for geolocation data, provision of the alternate organization and equivalent responsive materials would be greatly appreciated.

The requested documents will be made available to the general public. This request is being made in the public interest and is not being made for commercial purposes.

In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.

Sincerely,

Beryl Lipton
Investigative Researcher, Electronic Frontier Foundation
beryl.lipton@eff.org