NINERS mOBILE.
Updated on 24/09/2019
Updated on 24/09/2019
Niners Design APPS Developer does not collect data from our applications.
Our apps use third party SDK for use in ads for our customers.
These SDKS use data to improve ad campaigns for our customers.
Check out our partners' privacy policy for using ads and data.
Appodeal, Inc., a Delaware corporation has developed this Privacy Policy (“Policy”) to demonstrate our commitment to protecting our users’ privacy. The terms “Appodeal,” “we,” “us”, and “our” include Appodeal, Inc. and any affiliates and subsidiaries. The terms “you” and “your” refer to any individuals and entities who use our Services or visit our Website (including our publishers, advertisers, demand partners, and other service providers) and our Employees.
This Policy describes our online and offline information practices, the kinds of information we may collect, how we intend to use that information, with whom your information may be shared, and how you can opt-out of such uses or correct or change such information. By using our Services or our Website, you agree to the practices described in this Policy. This Policy is an integral part of and is incorporated by reference into our Terms of Service (the “Terms”). Any capitalized terms used but not defined in this Policy will have the meaning defined in the Terms.
This Policy applies to any information relating to an identified or identifiable natural person (“Personal Information”) that is collected, recorded, stored, adapted, used, or otherwise made available (collectively, “Processed”) by Appodeal in the course of our business providing an ad mediation platform, tools and other services (the “Services”) or the functionality of the Website. All individuals and entities whose responsibilities include Processing Personal Information on our behalf are expected to protect that data by adherence to this Policy. This Policy is intended to meet requirements globally, including those in North America, Europe, APAC, and other jurisdictions.
The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Appodeal and the requirements of applicable law. Appodeal may collect Personal Information in the following ways:
You may provide Personal Information directly to Appodeal through interacting with the Services or our Website, participating in surveys, during events, and requesting products, Services, or information.
As you interact with the Services or our Website, certain passive information may also be collected about your visit, including through Technologies as described below. We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
(a) Types Of Personal Information Appodeal Collects
Appodeal collects Personal Information regarding its current, prospective, and former clients, customers, publishers, demand partners, users, visitors, guests, and Employees (collectively “Individuals”).
Information You Provide Directly to Us. When you use the Services or the Website or engage in certain activities, such as registering for an account with Appodeal, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:
Account Registration. When you register for an account to access our Services, we collect information about you which may include your name, address, telephone number, email address, and billing information such as your credit card number.
Communications with Us. We may also collect Personal Information from you such as your name, email address, phone number or mailing address when you choose to request information about our products and Services, register for a newsletter, contact customer service, or otherwise communicate with us.
Surveys. From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products, Website and/or Services and in any manner consistent with the policies provided herein.
Automatic Data Collection. We may collect certain information automatically through our Services, Website, or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile advertising identifiers, and other device identifiers that are automatically assigned to your Device when you access the Internet, location data, browser type, operating system, Internet service provider, pages that you visit before and after using the Website or our Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view on our Website, and other actions taken through use of the Website or Services such as preferences.
Information from Other Sources. We may also obtain information about you through Third-Party services and organizations to supplement information provided by you. This supplemental information allows us to verify information that you have provided to Appodeal and to enhance our ability to provide you with information about our business, products, and Services.
(b) Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
We, as well as third parties that provide content, advertising, or other functionality on our Services or Website, may use cookies, pixel tags, local storage, mobile device identifiers and other technologies (“Technologies”) to automatically collect information through the Services or Website. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “Device”) that allow us to record certain pieces of information whenever you visit or interact with our Services, and to recognize you across Devices.
Cookies. Cookies are bits of data stored on your Device through your browser or mobile application that allow the mobile application to remember you the next time you visit. Cookies enable smoother, more efficient use of the Website by storing your specific information and preferences such as theme, language setting, privacy preferences, and even user ID and password, so you do not need to reenter those each time you visit the Website. You may choose to block or delete cookies if your browser permits, but doing so may affect your use of the Website and your ability to access certain features of the Website.
Advertising Identifiers. We may also use mobile advertising identifiers to recognize your device and perform the services. Depending on your device, you can chose to change or limit the transmission of your mobile advertising identifier by going into your device settings.
Web Bugs/Pixel Tags/Web Beacons. We may also use web bugs (also called web beacons) to help us understand the behavior of our users by allowing us to track user demographics and traffic patterns.
Social Media Widgets. Our Website includes social media features such as the Facebook “Like” button and LinkedIn (that might include widgets such as the share this button or other interactive mini-programs). These features may collect information including your IP address and which page you are visiting on our Website, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing it.
Analytics. We may also utilize Google Analytics and Yandex Metrics in the collection, compilation and analysis of information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/ . You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout You can out opt of Yandex Metrics by going to https://yandex.com/support/metrica/general/opt-out.xml
Our uses of such Technologies fall into the following general categories:
Operationally Necessary. We may use Technologies that are necessary to the operation of our Services or Website. This includes Technologies that allow you access to our Services; or that are required to identify irregular Website behavior, prevent fraudulent activity and improve security;
Performance Related. We may use Technologies to assess the performance of our Services or Website, including as part of our analytics practices, to help us understand how our visitors use our Website, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our Services or Website;
Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services or Website. This may include identifying you when you sign into our Website or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our Website;
Advertising or Targeting Related. We may use first-party or Third-Party Technologies to deliver content, including ads that may be relevant to your interests, on our Website or on Third-Party websites. This includes using Technologies to understand the usefulness to you of the advertisements and content that have been delivered to you, such as whether you have clicked on an advertisement.
We may also combine the information we collect through Technologies with other Personal Information we have collected from and about you. If you would like to opt out of the Technologies we employ through our Services, you may do so by blocking, deleting, or disabling them as your browser or Device permits.
(c) How Appodeal Uses Your Information
We acquire, hold, use, and Process Personal Information based on the legal grounds and for the legitimate business purposes outlined in this Policy, such as:
To Provide Services or Information Requested: Appodeal may use information about you to fulfill requests for Services or information, including information about potential or future Services, including to:
Generally manage Individual information and accounts;
Respond to questions, comments, and other requests;
Provide access to certain areas, functionalities, and features of Appodeal’s Services or Website;
Allow you to register for events.
Administrative Purposes: Appodeal may use Personal Information about you for its administrative purposes, including to:
Ensure you have a personalized and consistent experience in using the Website and Services;
Protect the security of our Service and Websiteand to prevent fraud;
Measure interest in Appodeal’s Services
b and perform analytics;
Notify you of changes to the Website or Services;
Develop new Services;
Ensure internal quality control;
Verify Individual identity;
Communicate about Individual accounts and activities on Appodeal’s Services, Website and systems, and, in Appodeal’s discretion, changes to any Appodeal policy;
Send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;
Process payment for Services purchased;
Process applications and transactions;
Prevent potentially prohibited or illegal activities;
Enforce our Terms of Use.
Marketing Appodeal Services: Appodeal may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Appodeal may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
To tailor content, advertisements, and offers;
To notify you about offers, products, and services that may be of interest to you;
To provide Services to you and our sponsors;
For other purposes disclosed at the time that Individuals provide Personal Information;
Otherwise with your consent.
You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described in Section 6 below.
Research and Development: Appodeal may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us improve our Website, to optimally deliver our existing Services or develop new Services. From time to time, Appodeal may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the Services we provide. The survey responses may be utilized to determine the effectiveness of our Services or our Website, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
Direct Mail, Email and Outbound Telemarketing: Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on Appodeal’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 6 below.
Mobile Devices: Appodeal provides Services that are specifically designed to be compatible and used on mobile Devices. Appodeal will collect certain information that your mobile Device sends when you use such Services, like a GPS location, user settings and the operating system of your Device. Appodeal’s Services require that users log in with an account, and information collected through mobile versions of the Services is associated with user accounts. In addition, Appodeal may enable Individuals to download an application, widget, or other tool that can be used on Devices. Some of these tools may store information on Devices. These tools may transmit Personal Information to Appodeal to enable Individuals to access user accounts and to enable Appodeal to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. Appodeal may use personal or non-identifiable information transmitted to Appodeal to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Policy or in other notices Appodeal provides.
Anonymous and Aggregated Information: Appodeal may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the Device from which you access Appodeal’s Services or Website, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services or Website. Anonymized or aggregated information is not Personal Information, and Appodeal may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Appodeal and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
Sharing Content with Friends or Colleagues: Appodeal’s Services may offer various tools and functionality. For example, Appodeal may provide functionality on its Services that will allow you to forward or share certain content with a friend or colleague. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Appodeal or any other Third Parties for any other purpose.
Other Uses: Appodeal may use Personal Information for other purposes for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
(d) Third-Party Websites and Social Media Platforms
The Website may contain links to other websites and other websites may reference or link to our Website or other Services. These other domains and websites are not controlled by us, and Appodeal does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application that they interact with. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
The Website and our Services may also contains links and interactive features with various social media platforms. If you already use these platforms, their cookies may be set on your Device when using our Website or Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
(e) Software Development Kit
To provide our Services, we offer a software development kit (“SDK”) which allows us to access your Mobile Properties. We may collect Personal Information about users of your Mobile Properties through our SDK, including IP addresses, mobile advertising IDs, GPS location (if appropriate permission is given), application usage statistics such as launch times and duration, ad views and click-throughs. Advertisers or demand partners that provide content through our SDK may also collect Personal Information or other information about your users through our SDK. You agree that, in order to use our SDK, you will obtain appropriate consent from your users for the collection, use and sharing of Personal Information through our SDK, and that you will maintain and process all user data in accordance with your privacy policy and all applicable laws in any country in which your Mobile Properties are distributed or used and users are located.
If you use our SDK as a publisher, you agree that we may also share certain non-personal information about your use of the SDK through your Mobile Properties with advertisers and demand partners who provide content through our SDK. Such information may include the number of requests you receive for ad placements on your Mobile Properties, the number of impressions and click-throughs generated, information about revenue you receive, and eCPM data.
Appodeal collects Personal Information from Employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). “Employees” include current, temporary, permanent, prospective or former employees, directors, contractors, workers, or retirees of Appodeal. The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy. We may also collect sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave; and information about national origin or immigration status.
We acquire, hold, use and Process Human Resources-related Personal Information for a variety of business purposes including:
Workflow management, including assigning, managing and administering projects;
Human Resources administration and communication;
Payroll and the provision of benefits;
Compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs;
Job grading activities;
Performance and employee development management;
Organizational development and succession planning;
Benefits and personnel administration;
Absence management;
Helpdesk and IT support services;
Regulatory compliance;
Internal and/or external or governmental compliance investigations;
Internal or external audits;
Litigation evaluation, prosecution, and defense;
Diversity and inclusion initiatives;
Restructuring and relocation;
Emergency contacts and services;
Employee safety;
Compliance with statutory requirements;
Processing of Employee expenses and travel charges;
Acquisitions, divestitures, and integrations.
(a) Information We Share
We may share your information as described in this Policy (e.g., with our Third-Party service providers; to comply with legal obligations; to protect and defend our rights and property) or with your permission. The complete Third-Party service provider list can be found here: www.appodeal.com/home/partners-privacy-policies/
We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers, including advertisers that provide content through our SDK. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services, such as web hosting or data management; (ii) provision of information and services you have requested; (iii) payment processing; and (iv) customer service activities; and (v) in connection with the provision of the Website. Appodeal has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
Business Partners. We may choose to share Personal Information with our business partners and affiliates for our and our affiliates’ internal business purposes, or to provide you with Services that you have requested. Appodeal may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Appodeal’s. Appodeal requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Appodeal provided it to them.
Interest-Based Advertising and Third Party Marketing. Through our Services, Appodeal may allow Third-Party advertising partners to set tracking tools (e.g., cookies or other Technologies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Appodeal related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Website to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt-out of such sharing at no cost by following the instructions in Section 6 below.
Disclosures to Protect Us or Others (e.g., As Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Appodeal policies or contracts; (v) to collect amounts owed to Appodeal; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
In addition, from time to time, server logs may be reviewed for security purposes—e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. Should such an event occur, Appodeal will endeavor to direct the transferee to use Personal Information in a manner that is consistent with the Policy in effect at the time such Personal Information was collected.
(b) Data Transfers
All Personal Information collected via or by Appodeal may be stored anywhere in the world, including but not limited to, in the United States, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Appodeal, you consent to the storage of your Personal Information in these locations.
6. Choice/Modalities to Opt-Out
(a) General
You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to Appodeal’s Processing of your Personal Information or sensitive Personal Information, you may withdraw that consent at any time and opt-out to further Processing by following the instructions in this Section. Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Website and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
(b) Email and Telephone Communications
If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain communications regarding Appodeal and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms or this Policy).
We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.
(c) Human Resources Data
With regard to Personal Information that Appodeal receives in connection with the employment relationship, Appodeal will use such Personal Information only for employment-related purposes as more fully described above. If Appodeal intends to use this Personal Information for any other purpose, Appodeal will notify the Individual and provide an opportunity to opt-out of such uses.
(d) Do Not Track
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
(e) Cookies and Interest-Based Advertising
We hope that you find the display of interest-based Ads valuable. However, if you wish to opt-out of these advertising services, you can edit your preferences by visiting the “Settings” page of the Website and selecting the option to opt-out.
As noted above, you may stop or restrict the placement of cookies on your Devices or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile Devices, application users may opt out of certain mobile ads via their Device settings or by downloading the AppChoices mobile application offered by the Digital Advertising Alliance.
The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at networkadvertising.org/managing/opt_out.asp, or www.youronlinechoices.eu and www.aboutads.info/choices/. You can also choose not to be included in Google Analytics by following this link: tools.google.com/dlpage/gaoptout
To be clear, whether you are using our opt-out found at www.appodeal.com/home/sdk-opt-out and/or an online industry opt-out, these cookie-based opt-outs must be performed on each Device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile Device. You must separately opt-out on each Device. Advertisements on Third-Party websites that contain the AdChoices link and that link to this Privacy Policy may have been directed to you based on anonymous, non-Personal Information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt-out of the advertising partners’ use of this information for interest-based advertising purposes.
The security of your Personal Information is important to us. We maintain appropriate safeguards and current security standards to protect your Personal Information from unauthorized access, disclosure, or misuse, such as using SSL encryption. However, no system can be completely secure, and we cannot ensure or warrant the security of any information you provide to us. While we take meaningful steps to secure your information, we do not promise, and you should not expect, that your Personal Information will always remain secure. We do not accept liability for unintentional disclosure.
By using the Website or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Website. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Website or sending an e-mail to you. You may have a legal right to receive this notice in writing.
You can review and change certain Personal Information related to your use of our Website or Services (such as your name and contact information). To access your information, simply sign in to your account and you will be able to edit your Personal Information.
You may inquire as to whether Appodeal is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate. Where otherwise permitted by applicable law, you may send an e-mail to legal@appodeal.com or use any of the methods set out in this Policy to request access to, receive (port), restrict Processing, seek rectification, or request erasure of Personal Information held about you by Appodeal. Such requests will be processed in line with local laws.
| Although Appodeal makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Appodeal is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Appodeal determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Appodeal will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
Appodeal retains the Personal Information we receive as described in this Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
The Website is restricted to individuals over the age of 18. We do not knowingly collect, maintain, or use Personal Information from children under 13 (and in certain jurisdictions under the age of 16) years of age, and no part of the Website is directed to children under the age of 13 (and in certain jurisdictions under the age of 16). If you learn that your child has provided us with Personal Information without your consent, you may alert us at legal@appodeal.com. If we learn that we have collected any Personal Information from children under 13 (and in certain jurisdictions under the age of 16), we will promptly take steps to delete such information and terminate the child’s account.
By using the Website, you will transfer data to the United States. If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and processing globally. By providing your Personal Information, you consent to any transfer and processing in accordance with this Policy.
Questions or concerns regarding our compliance with this Policy may be directed to legal@appodeal.com or contact us at:
Appodeal, Inc.
350 Alabama Street Unit 10
San Francisco, CA 94110
Appodeal will address your concerns and attempt to resolve any privacy issues in a timely manner.
If you are an EU citizen and feel that Appodeal is not abiding by the terms of this Privacy Policy, please contact us at the contact information provided above. If any request remains unresolved, you may contact the national data protection authority for your EU Member State.
(a) CHANGES TO OUR PRIVACY POLICY AND PRACTICES
Revision to the Privacy Policy. We may revise this Privacy Policy in our sole discretion, so review it periodically. If you continue to visit this Website or use our Services after such changes have been made, you hereby provide your consent to the changes.
Posting of Revised Privacy Policy. If there are any material changes to this Policy, Appodeal will notify you by email or as otherwise required by applicable law. We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective immediately when it is posted (or upon notice as applicable). If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.
New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt-out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, Appodeal will endeavor to comply with the law or contract.
CALIFORNIA PRIVACY RIGHTS
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Appodeal does not share Personal Information with Third Parties for their own marketing purposes.
The last update to our Privacy Policy was posted on May 3, 2018.
READ THE POLICIES IN
END USER PRIVACY POLICY
StartApp End User Privacy Policy
StartApp Inc. and its Affiliates (“we,” “us,” “our” or “StartApp”) respects your privacy. This privacy policy (the “Policy”) explains StartApp’s privacy practices with respect to your personal information throughout the entire StartApp Network, the ways your personal information and data is collected, used and shared and the rights and options available to you with respect to your personal data.
Who we are?
StartApp is a mobile advertising and data company that develops, operates and supports an advertising platform, solution and network (“StartApp Solution”) for the purpose of serving targeted and personalized advertisements to individuals (“End Users”) based on their profile.
For more information about StartApp, you may visit our website at: www.startapp.com or contact us at support@startapp.com.
Introduction with StartApp Network.
StartApp Solution collects and processes your personal data, location and other data from several sources (such as through StartApp SDK (software development kit) embedded or integrated in variety of mobile apps , StartApp RTB (real time bidding) platform used for placement of ads on real time (RTB), supply side platforms or partners, advertisers, and other data providers; together: “Data Sources”).
StartApp shares or makes available such data (or part of it) with the following third parties (i) advertisers which run their campaigns on StartApp inventory (mobile apps engaged directly with StartApp or indirectly through other advertising networks or platforms; “Advertisers”); (ii) advertising agencies and other business partners, which run their campaigns on StartApp inventory or on their independent inventory, and can be “processors” or “controllers” of the data (together: “Business Partners”); and (iii) third parties which run or operate their own data bases, solutions or platforms which may act as “controllers” of data and may use your data together with other data they process about you (“Data Partners”).
“StartApp Network” means the advertising network of StartApp which includes Data sources on the one hand and Advertisers, Business Partners and Data Partners on the other hand, whereby your data is collected, processed, used, made available and shared for the Purpose (as defined below).
Purpose of Data Processing.
Your data is collected, processed, used and shared by StartApp throughout StartApp Network for the purpose of serving you targeted and personalized advertisements based on your profile (the “Purpose”). When we share your data with third parties (Advertisers, Business Partners and/or Data Partners) we will contractually obligate them to use the data for the Purpose only, other than if they represent that they can use it for other purposes subject to your consent or other lawful basis.
Stop Receiving Advertisements; contact our support at support@startapp.com
Please note that it is not StartApp’s decision to display ads within the mobile app you use, but the app’s developer or publisher who uses our services (directly or indirectly). However, we believe that you benefit from these apps, since in most cases, displaying Advertisements is essential for keeping publishers’ apps and services free of charge. Moreover, when app’s developer or publisher uses our services (directly or indirectly) Advertisements provided to you may be optimized and/or customized to you, which improves your experience with the app.
If you wish to stop receiving Advertisements, you should contact the app’s developer or publisher, whose details you can find on Google Play or Apple App Store, and submit your request to it. Alternatively, you may change your mobile phone settings (IOS / Android).
You may contact us at support@startapp.com and we will do our best to help you.
Opting out.
You have the choice to opt-out from the entire StartApp Network and/or from sharing of your personal data with our Data Partners, by clicking your preferred choice under Section 12 (Opt-out Rights) below. By opting out, your experience with Advertisements provided to you within StartApp Network will not be optimized or customized to you.
StartApp may be a controller or processor of your personal data, considering the way data is collected by or through each Data Source and its usage by us or each of our Advertisers, Business Partners or Data Partners.
You hereby agree to the use of: (a) electronic means to consent to and complete this Policy and to provide you with any notices given pursuant to this Policy; and (b) electronic records to store information related to this Policy.
Our Privacy Policy in a Glance
Section
Summary
2
Information we collect directly or indirectly from you
We will collect, process, use and share (pursuant to this Policy) the following data if available to us: your Advertising ID, Internet Protocol addresses, Location, name of app (where our SDK is installed), gender and age (if shared with or assumed by us), data of a query of installed apps, device properties, Bluetooth paired devices, device sensors, carrier, ISP, network connection details and Wi-Fi data, roaming, local time zone, language settings, your interests and behavioral data assumed from keywords shared with us.
3
Collection of your Location
We will collect, process, use and share (pursuant to this Policy) the following data if available to us: exact location (if you provide a permission to the App where our SDK is installed or embedded).
We will assume your location if you are connected to Wi-Fi and/or mobile network cell whose assumed location is known to us.
Your country, city and region may be available to us from your IP or other Data Sources.
4
Information we collect from your interaction with Advertisements or from Advertisers
When you interact with an Advertisement, advertising attribution and measurement will be shared with us. We may receive post click usage and/or activity within mobile apps which Advertisement leads to these apps or the app services.
5
Process of Sensitive Information
StartApp does not require nor does it knowingly or intentionally collect, solicit or otherwise process any Sensitive Information from or of End Users
6
Children’s Privacy
StartApp does not knowingly or intentionally collect or solicit personal information from children (as they are defined under applicable law).
7
Use of your personal information for personalized, targeted Advertisements
We will use (including: sell, license or share) the information collected by or shared with us for the Purpose, i.e.: serving targeted and personalized advertisements to you based on your profile and activity.
8
Use of your information for other purposes
We will use the information collected by or shared with us for other purposes as well, such as: improve StartApp Solution, develop new services update or upgrade existing services; operate, maintain, protect and manage StartApp Solution; audit and track usage statistics and traffic flow; detect fraud in connection with StartApp Solution; enforce this Policy and prevent unlawful activities; and comply with any applicable laws.
9
Sharing Data with third parties
We may share your data (or part of it) with Advertisers, advertising networks, Business Partners and/or Data Partners; attribution partners; competent authorities; our affiliated corporate group entities; and in the event of merger, sale or transfer of all or a portion of our assets or shares or other reorganization or reconstruction in our ongoing business.
10
Cookies and Data Collection by Third Party
If you open a mobile webpage from an App where our SDK is installed or embedded, we may place a cookie on your device mobile browser with your Advertising ID which will be used by us for the Purpose.
11
Non-personal and/or anonymized data
Non-personal and/or anonymized data may be collected, processed and used by us in any way.
12
Opt-Out Rights
You may easily opt-out of certain data collection, sharing process and targeted advertising related to StartApp Network, by sending us an email to privacy@startapp.com, and elaborating what service you choose to opt-out from.
13
Your Choices and Controls
You have the right to exercise any of the following rights, subject to and in accordance with the laws apply to you, by sending us an email to dpo@startapp.com, which elaborates the right(s) you would like to exercise: withdraw consent; object, erasure (be forgotten), access your data, data portability.
14
Data Security
We have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry standards.
15
Data Retention
We retain personal data we collected, in accordance and compliance with applicable laws, but in any event, we will not use your personal information for the Purpose during more than 12 months.
16
Transfer of data outside your territory
We may store or process your personal data in the United States or in other territories. Subject to the laws apply to you, your consent to this Privacy Policy includes your express consent for such transfer of your data.
17
Changes to The Policy
This Policy may be updated by us from time to time. The most up-to-date Policy as well as any updated to this Policy will be published and will be available in the following link: https://www.startapp.com/policy/privacy-policy/.
18
Contact Us
You can also contact us via email at: Support@startapp.com.
19
Data Protection Officer
You may contact our Data Protection Officer at: dpo@startapp.com.
Information we collect directly or indirectly from you through our Data Sources
We will collect and process the following data (or part of it – considering the technology or integration used, the data available to us and other permissions), if you download an App, which our StartApp SDK is installed or embedded in, and/or if your data is shared with us, when we are integrated with or connected to other advertising networks, agencies or platforms (such as RTBs):
(a) Online identifiers: Advertising ID (IDFA for iOS devices and AAID for Android devices) (“ADID”).
(b) Internet Protocol (“IP”) addresses.
Please note that, while ADID and IP address are considered as personally identifiable data in many jurisdictions (such as the EEA), there are some jurisdictions in which such data is not considered as Personal Data.
(c) Location – as detailed in Section 3 below.
(d) Name of App (where the SDK is installed) and its category; for non SDK: name of the mobile application through which you interact with StartApp Network.
(e) Gender and age (whether as conclusion made by us or strictly shared with us by other Data Source)
(f) Data of a query which asks whether certain apps are already installed in your mobile device (one-way hash representation).
(g) Other general data: device properties (operating system, operating system version and device type), Bluetooth paired devices, device sensors (such as the accelerometer), your carrier, ISP, network connection details and Wi-Fi data, roaming, local time zone, language settings.
StartApp SDK is a piece of software which is integrated into or embedded in mobile apps which enable these apps’ developers, owners or operators to provide you as well as other end users with personalized Advertisements.
“Advertisement” or “Ad” means any sort of advertising materials, including text, images, video, ads, content, photo, sounds, graphics, music, logos and any other materials or content promoting the goods and services or mobile application, software, etc., provided, enabled, supported or facilitated by StartApp Network.
“RTB” means “real time bidding” platform or solution whereby advertising inventory is bought and sold on a per-impression basis, via programmatic instantaneous auction, which is based, in most cases, on the user’s data which is shared with the bidder (advertiser or advertising network, such as StartApp). Advertiser who wins the bid display its advertisement to that user on the bidding inventory.
Collection of your location
Your location may be available to us through any of the following instances (together: your “Location”):
(a) We may collect your exact location, via your mobile phone, if you provide permission and consent to share your location with an App (which StartApp SDK is installed or embedded in). Please note that we do not collect a real time location but your last known location which is available to our SDK.
(b) We may assume your location, if you are connected to a Wi-Fi whose assumed location is known to us.
Please note that we will not be able to collect your location in accordance with subsections (a) and (b) above if you cancel the permission you granted to the App(s) (which are SDK is installed or embedded in) to collect your location.
(c) We may assume your location by collecting the data with respect to the mobile network cell which you are connected to, if the location of that cell is known to us.
(d) Your country, city and region may be available to us from your IP collected by the SDK or other Data Sources or from other data shared with us by third parties (for example through RTB integration).
Please note that by disabling your geo-location permission to an App (through the mobile device operating system), your location may still be assumed and/or collected by us from other available sources detailed in sub-sections (b), (c) and (d).
You may opt-out of location-based services at any time by editing your device’s settings. In addition, you may opt-out from sharing your location with us by all sources, as detailed in Section 12 (Opt-out Rights) below.
Information we collect from your interaction with Advertisements or from Advertisers
When you interact with an Advertisement provided, supported or enabled by us, the advertising attribution and measurement will be shared with us by third party services (known as “attribution partners”). We will use this data for frequency cap (e.g.: if and when to present you a similar Advertisement) and advertising attribution and measurement.
In addition, mobile apps publishers, developers and/or owners, which the Advertisement leads to their mobile apps (including incentivize installation of the mobile app) and/or services may share with us your post click usage and/or activity within their mobile apps or services following your interaction with the Advertisement. Such usage and/or activity may include purchases you make (including amount), subscriptions you purchase and level progress (in games). This information will be used by us for optimizing future advertising campaigns of these mobile apps’ publishers, developers and/or owners through StartApp Network, as well for the Purpose detailed in Section 8 below.
Process of Sensitive Information
StartApp does not require nor does it knowingly or intentionally collect, solicit or otherwise process any Sensitive Information from or of End Users.
The term “Sensitive Information” may have different meaning in different jurisdictions, and may include: racial, ethnic or communal origin; political affiliations or opinions; religious or philosophical beliefs or other beliefs of a similar nature; intimate affairs or sexual life; financial data, credit worthiness data, financial account, payment card number; criminal record; political parties or trade-union membership; and physical or mental health or condition, health insurance, medical and/or biometric data.
If you become aware or have any reason to believe that you were requested to provide any Sensitive Information, or that StartApp Network processed any information which may be considered as Sensitive Information, please contact us at privacy@startapp.com and we will take steps to ensure that such Sensitive Information will be immediately deleted from our files. Please note that the definition of “Sensitive Information” may not have the same meaning in different jurisdictions.
Children’s Privacy
StartApp complies with applicable legislation related to children’s privacy protection, including the US Children’s Online Privacy Protection Act (“COPPA”). Thus, we do not knowingly or intentionally collect or solicit personal information from children, as they are defined under applicable law, and specifically: under the age of 13 years old, if they are located in the US, or under the age of 16 years old, if they are located in the EU; (collectively: “Child” or “Children”), except as permitted under applicable law.
If we obtain actual knowledge that an End User is considered as a child under applicable law, and we processed personal information with respect to that End User (other than as permitted under applicable law) we will take immediate steps to delete his/her personal information. In addition, we request that Children will not voluntarily provide us with any personal information through StartApp Network.
If you become aware or have any reason to believe that a Child has shared any Personal Information with us, please contact us at privacy@startapp.com and we will take steps to ensure that such personal information is immediately deleted from our files, to the extent required under applicable law.
Use of your personal information for personalized, targeted Advertisements
We will use (including: sell, license or share) the information collected by or shared with us for the Purpose, i.e.: serving targeted and personalized advertisements to you based on your profile and activity.
Your profile is a probabilistic output of our analysis, assumptions and conclusions in regard of your behavior, interests and intentions, based on the information we collected by or shared with us from all Data Sources, as detailed above, and unified by us to a single database about you.
Please note that targeted and personalized Advertisements may be served to you by us on our inventory and/or by our Business Partners or Data Partners, which we share your data with. Please note that once we share your data with a third party, the data becomes subject to that third-party privacy practices.
The list of Business Partners or Data Partners which asked us make their privacy policy available to you is available at: https://www.startapp.com/startapp-data-partners-list/.
In those jurisdictions which require lawful basis for process of personal information: the legal basis for processing of your personal information for the Purpose is your consent, which may be provided by you directly to us or indirectly through third parties(such as by RTB signal or signals). Your consent to us may be general (for all data we collect, process use and/or share) or in regard of specific data shared with us in certain event(s) (such as data shared together with RTB signal or signals). We will comply with the scope of your consent provided to or shared with us.
Please note that when certain data is shared with us by a third party with a “no consent” signal (or equivalent signal), it does not affect your consent to us in general or through other signals (with a “consent” signal), nor is it considered by us as exercising your rights under section 12 (Opt-Out Rights) or section 13 (Your Choices and Controls), which has to be exercised as detailed herein.
Please refer to section 12 (Opt-Out Rights) and section 13 (Your Choices and Controls) section below for opting out from StartApp Network or exercising other rights granted to you in accordance with any applicable law.
Use of your information for other purposes
The information we collect, and which is shared with us will be used for the following additional purposes:
(a) To improve StartApp Solution, develop new services update or upgrade existing services and to enhance your experience with StartApp Solution.
(b) To operate, maintain, protect and manage StartApp Solution, and to manage other administrative and operational aspects of our StartApp Solution.
(c) To audit and track usage statistics and traffic flow, and detect fraud in connection with StartApp Solution.
(d) To protect the rights or property of StartApp or third parties.
(e) To enforce this Policy and prevent unlawful activities and misuse of StartApp Solution.
(f) to establish or exercise our rights to defend against legal claims.
(g) to prevent harm to the rights, property or safety of us, our users, yourself or any third party or for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights.
(h) To comply with any applicable laws and assist law enforcement agencies when we have a good faith belief that our cooperation with them meets the applicable legal standards.
(i) To take any action in any case of dispute involving you with respect to StartApp Solution.
In those jurisdictions which require lawful basis for process of personal information, the usage of your data for the above purpose is based on our legitimate interests of: (i) operating, providing, maintaining, protecting, managing, customizing and improving StartApp Solution (your ADID is not required for performing these actions); (ii) auditing and tracking usage statistics and traffic flow, detect fraud in connection with StartApp Solution and calculate payments (your personal information is not required for performing these actions); and (iii) protect the rights or property of StartApp or third parties.
Sharing Data with third parties
We may share your data (or part of it) in accordance with the following:
(a) We will share, license, sell, transfer or make available your data (or part of it) with Advertisers, advertising networks, Business Partners and/or our Data Partners which may use it while serving you targeted and/or personalized advertisements, as detailed in Section 7 (Use of your personal information) above, and pursuant to your consent as detailed there.
(b) We will share ADIDs collected by us, with attribution partners for the purpose of measurement and attribution of the Advertising, which is used for calculate payments, detect invalid traffic (fraud), security or technical issues in connection with StartApp Solution.
(c) If you have breached the terms or this Policy, abused your rights to use the App, or violated any applicable law, or in any other case of dispute, or legal proceeding of any kind involving you with respect to the App, your information may be shared with competent authorities and with any third party, as may be required.
(d) We may share information that we collect or obtain through the App with the relevant authorities, entities or persons if we are required by law to share or disclose your information.
(e) Personal identifiable information may be shared with, or transferred to, our affiliated corporate group entities (entities controlled by, under common control with, or controlling us, directly or indirectly; “Affiliates”), but their use of such information must comply with this Policy.
(f) Upon bankruptcy, dissolution or other liquidation or insolvency events or in the event of merger, sale or transfer of all or a portion of our assets or shares or other reorganization or reconstruction in our ongoing business, the information that we receive, collect or obtain, as outlined in the preceding sections, may be shared with or transferred to, that respective entity to the extent strictly necessary for continued provision of services, provided that it will undertake to be bound by the provisions of this Policy, with reasonably necessary changes taken into consideration. Upon such transfer or sharing of information, that entity will assume full and exclusive responsibility for all subsequent use and processing it makes of the information and we will be released from any liability to you, regarding the succeeding entity’s use and processing of the information by it.
(g) In any case other than the above mentioned in this Policy, your personal identifiable information will be shared with others only if you provide your consent, as described in Section 7 (Use of your personal information) above.
In those jurisdictions which require lawful basis for process of personal information, sharing of your data pursuant to subsection (a) is based on your consent, as described in Section 7 (Use of your personal information), and for other subsections is based on our legitimate interests.
Cookies and Data Collection by Third Party
If you open a mobile webpage from an App where our SDK is installed or embedded, we may place a cookie on your device mobile browser with your Advertising ID which will be used by us for the Purpose (serving targeted and personalized advertisements to you on that mobile browser) (the “Cookie”). When running advertising campaigns, provided, enabled or supported by us on your mobile browser, the Cookie will enable us to identify you as the user of the mobile browser and personalize you accordingly.
Most browsers will allow you to erase cookies from your device, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies your experience may be limited. For more information about cookies and your controls in this regard, you may review the following links:
– https://support.google.com/chrome/answer/95647?hl=en (Chrome);
– https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
– http://www.opera.com/help/tutorials/security/cookies/ (Opera);
– https://support.apple.com/kb/PH21411 (Safari); and
– https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge)
Non-personal and/or anonymized data
We may collect, process and use non-personal and/or anonymized data, which does not identify you personally (which includes personal data which has been further anonymized). Such non-personal and/or anonymized data may be collected, processed and used by us in any way, including by posting, disseminating, transmitting, sharing or otherwise communicating or making it available to third parties.
For example, StartApp’s SDK includes Open Measurement Software Development Kit by IAB TECH LAB (“OM SDK”) for the purpose of verifying that ads were actually viewed. We do not share any personal data with IAB or through the OM SDK.
Opt-Out Rights
You may easily opt-out of certain data collection, sharing process and targeted advertising related to StartApp Network, by sending us an email to privacy@startapp.com, and elaborating what service you choose to opt-out from.
Please note that we may have to contact you, if we have to verify your identity, within fourteen (14) days from receiving your application to us. You hereby agree that we will use your email for that purpose.
We will exercise your request within thirty (30) days from receiving it or verifying your identity (as applicable).
Opting-out provides you with the choice to receive advertisements that are not targeted to you and to control the data collected on you for the purpose of displaying Advertisements. Please note that even if you opt-out, you may still receive Advertisements from StartApp Network, but subject to your opt-out choice, such Advertising will not be personalized or targeted by us.
Your Choice
Effect of opting out
Opt-out from StartApp Network.
(i) we will (a) anonymize your data by deleting your ADID (which makes sure you cannot be identified personally); and/or (b) delete your personal data – as further described in Section 15 (Data Retention);
(ii) Advertisements provided or supported by StartApp Solution will not be customized to you and may be not relevant to you, which will limit your experience with StartApp Solution;
(iii) we will share your choice with our Advertisers, Business Partners and Data Partners, and ask them to either delete your personal data or make your data unidentifiable by anonymizing it.
Stop sharing your location with us and with our Advertisers, Business Partners and Data Partners
(i) we will stop collecting your location in all means detailed in Section 3 of this Policy;
(ii) we will anonymize your Location data;
(iii) we will share your choice with our Advertisers, Business Partners and Data Partners, and ask them to either delete your location data or make your location data unidentifiable by anonymizing it.
Stop sharing your data with our Data Partners; and/or
Opting-out from Data Partners
(i) we will not share your ADID with our Data Partners;
(ii) we will share your choice with our Data Partners and ask them to either delete your personal data or make your data unidentifiable by anonymizing it.
Please note, however, that we are not responsible for the privacy practices of our Data Partners, and other third parties. You are encouraged to review the privacy policies of our Data Partners which are available at: https://www.startapp.com/startapp-data-partners-list/.
Opting-out from sharing your data with our Data Partners does not constitute an opt-out from the entire StartApp Network. Therefore, your data may be still processed by StartApp, Advertisers and Business Partners of StartApp. You may choose to opt-out from the entire StartApp Network, as described above.
Opt-out from placing our cookie on your mobile browser
We will not be able to support, enable or place Advertisements customized to you on your mobile browser.
In addition, you may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser (as detailed in the Cookie section above).
We do not respond to Do Not Track signals. For more information about Do Not Track signals, please see http://www.allaboutdnt.com/.
In addition to the above, you may limit the disclosure of certain data by your mobile device to us and our Advertisers, Business Partners and Data Partners by adjusting the settings on your mobile device.
– For iOS mobile Devices, go to “Settings” from your Device’s home screen; scroll down to “Privacy”; select “Advertising”; and turn on “Limit Ad Tracking.”;
– For Android mobile Devices, go to “Google Settings” on your Device; select “Ads”; and check the box labeled “Opt-Out of Interest-Based Ads.”
Please read your device specific information to learn more about your personal advertising preferences: Android: https://support.google.com/ads/answer/2662922;
iOS: https://support.apple.com/en-il/HT205223
You may also Contact Us and we will be happy to assist you.
Your Choices and Controls
In addition to your Opt-Out Rights (Section 12 above), you have the right to exercise any of the following rights, as well as other rights granted to you, subject to and in accordance with the laws apply to you which grant you such right(s) (if any) (“your Right(s)”). You can exercise your Right(s) by sending us an email to dpo@startapp.com, which elaborates the Right(s) you would like to exercise (such as: “Consent Withdraw”) (a “Request”). We may have to communicate with you in order to process your Request, including to verify your identity. By sending us a Request you hereby agree that we will communicate with you for that purpose.
Your Right
StartApp Action
A1. Consent withdraw
if the lawful basis for collection and processing of your personal information is your consent, you may withdraw your consent granted to us (directly or indirectly)
(i) we will (a) anonymize your data by deleting your ADID; or (b) delete your personal data – as described in Section 15 (Data Retention);
(iii) we will share your request with our Advertisers, Business Partners and Data Partners, and ask them to anonymize your data
We may contact you, if we have to verify your identity, within fourteen (14) days from receiving your Request.
We will exercise your Right within thirty (30) days from receiving your Request or verifying your identity (as applicable).
A2. Right to object
you may object to the processing of your personal data by us
A3. Right to erasure (to be forgotten)
Right to request us to delete or remove the personal information collected by or shared with us throughout StartApp Network
B1. Right of access /
B2. data portability
Right to receive a copy of the data collected by or shared with us throughout StartApp Network and/or transfer it to third party
We will send to your email address a copy of the data collected about you in the course of using StartApp Solution. You hereby agree and authorize us to send you such email and to communicate with you in order to process your Request, including to verify your identity, if required.
We will exercise your Right within fourteen (14) days from receiving your Request or verifying your identity (as applicable).
Following receipt of a copy of your data, you may ask us to rectify or delete that data (i.e. anonymizing it).
Exercise of above Rights will not affect the lawfulness of processing based on consent before they were exercised. We may continue to process information which your consent is not required for, subject to any applicable law. Note that, data privacy and related laws in your jurisdiction may provide you with different or additional rights related to your data, which may also apply.
Where we are not able to provide you with the data you have requested, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisor authority.
When we are in a position of a processor of your data, we will exercise the above rights if we receive a request from the data controller without validating your identity. In other circumstances, such validation may be a condition for exercising your Rights(s) by us.
After opting-out from StartApp Network and/exercising any of the rights under categories A1-3 above (i) we may continue to receive data about you from other entities which use StartApp Solution or throughout StartApp Network. Provided however that we will process your personal data for the purpose of serving ads based on data shared with us (i.e.: in our capacity as data processor only); (ii) we may serve you Advertisements that are not based on your profile or not targeted to you; (iii) we will continue with processing of data which does not require your consent; and (iv) if you grant us your reconsent (directly or indirectly, as stated above), we shall process your data pursuant to this Policy, provided that only data collected by or shared with us after your reconsent will be used by us for the Purpose.
Data Security
Your privacy is very important to StartApp and we are committed to protecting your Personal Data from unauthorized access, use or disclosure. We have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry standards. For more information on our security measures, please click here.
Although we take reasonable steps to safeguard information, unless stated otherwise by applicable laws, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Services, and we make no warranty, express, implied or otherwise, that we will be able to prevent such access.
Data Retention
We retain the personal data we collect, in accordance and compliance with applicable laws, and in accordance with the following:
– In any of the events detailed in Sections 12 (Opt-Out Rights) or 13 (Your Choices and Controls – categories A1-3) we will (i) anonymize your data by deleting your ADID stored in our operational database; and/or (ii) delete the personal data actually collected about you whose collection and process required your consent;
– We will not use your personal information for the Purpose during more than 12 months. We shall either delete from our operational database data whose age is more than 12 months or anonymize your data by deleting your ADID from our operational database (and thereafter we will not be able to use the personal data collected and processed about you for the Purpose).
Provided however that, when we delete or anonymize your ADID and/or your data from our operational databases, it will not be deleted from our archive, due to our platform technical design limitation, which makes it impossible to rewrite the entire code which consists your ADID. We have designed our platform in a way that your personal data, which is left in our archive following your request to opt-out from StartApp Network (or equivalent request) will not be processed, used or shared with any third party following such request.
Transfer of data outside your territory
We may store or process your personal data in the United States or in other territories. If you are a resident of the European Economic Area (“EEA“) we will take appropriate measures to ensure that your personal data receives an adequate level of data protection upon its transfer outside of the EEA.
If you are a resident of a jurisdiction where transfer of your Personal Data requires your consent, then your consent to this Privacy Policy includes your express consent for such transfer of your data.
Changes to The Policy
This Policy may be updated by us from time to time. Substantial changes will take effect 30 days from update. Other changes will take effect 7 days from update. If the Policy is amended to comply with legal requirements, the amendments will become effective immediately. The most up-to-date Policy as well as any updated to this Policy will be published and will be available in the following link: https://www.startapp.com/policy/privacy-policy/. We encourage you to review the Policy periodically to ensure that you understand how we collect, process, use and share your information through StartApp Network.
Contact Us
If you have any questions or comments about this Policy, please write to us at:
StartApp Inc.; 584 Broadway St. 12th Floor Suite 1206 New York, NY, 10012.
You can also contact us via email at: privacy@startapp.com.
Data Protection Officer
If you have any requests regarding the data collected under this Policy, including without limitation, requests to remove, delete, amend, modify or transfer the data, please contact our Data Protection Officer at: dpo@startapp.com
Please be sure to include your name, address and email address in any correspondence to us so that we can respond to your inquiry in a timely manner.
For your convenience, this Policy may be translated from English to several other languages. Please note that in any discrepancies or inconsistencies between the translation available to you (if any) and the English version, the English version (available at: link: https://www.startapp.com/policy/privacy-policy/) shall prevail.
Last update: September 1, 2019