INTRODUCTION
Appsumer is committed to protecting and respecting your privacy. This Privacy Notice explains what personal data and other information Appsumer collects as part of our activities, and how we use or process that information.
DEFINITIONS
For the purpose of this Privacy Notice, when we use the following words they will have the following meanings:
| “Agreement” | An agreement between Appsumer and a Client. |
| “Appsumer Platform” | Appsumer’s proprietary Software as a Service (SaaS) for advertising, analytics and workflow automation accessed by End Users as part of the Service. |
| “Appsumer Website” or “Our Website” | The website owned and managed by Appsumer that may be accessed at http://www.appsumer.io/. |
| “Data Controller” |
Means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be processed. For the purpose of the General Data Protection Regulations 2018 and in relation to the Appsumer Website, Appsumer are a Data Controller. For the purpose of the General Data Protection Regulations 2018 and in relation to the Appsumer Platform, the “Client” and “End-users” are the Data Controller. |
| “Data Processor” |
In relation to personal data, means any person (other than an employee of the Data Controller) who Processes the data on behalf of the Data Controller. For the purpose of the General Data Protection Regulations 2018 and in relation to the Appsumer Website, Appsumer are a “Data Processor”. For the purpose of the General Data Protection Regulations 2018 and in relation to the Appsumer Service, Appsumer are the “Data Processor”. |
| “Processing” | In relation to information or data means obtaining, recording or holding the information or data or carrying out any operation or set of operations on the information or data, including:
|
| “Visitor” | An individual visiting, or otherwise interacting with, our Website (http://www.appsumer.io/). |
| “Prospect” | An individual who has expressed an interest in Appsumer and/or The Appsumer Service and/or any individual who is deemed, by Appsumer, to have an interest in Appsumer and/or The Appsumer Service by the nature of their professional work and position. |
| “Client” | A company or other entity who is entitled to access and use the Appsumer Service, including data processing, pursuant to an agreement with Appsumer. |
| “End user” | Employees and other representatives of a “Client” who has access to and interacts with the Appsumer Platform. |
| “Data Subject” | An individual who is the subject of personal data. Appsumer treat the following as Data Subjects:
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| “Clients’ Users” | Individuals using our clients’ products and services. |
| “Personal Data”, “Personally Identifiable Information” or “PII” | Information from which the identity of a living individual may be determined. Examples of Personal Data include (but are not limited to) first and last name, home or other physical address, email address, phone number, IP address or other contact information, and credit card or other payment information. |
| “Service” | The Appsumer Platform and associated assistance provided to Clients and End Users, including but not limited to:
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To make it clearer and easier for you to review those parts of this Privacy Notice which apply to you, we have divided up the document into three sections:
- Section 1: Appsumer Website Visitors
- Section 2: Appsumer Platform End-users
- Section 3: General
SECTION 1: Appsumer Website Visitors & Prospects
This section describes what information is collected by Appsumer from Website Visitors, and how that information is used by Appsumer.
How do we collect information from Website Visitors & Prospects?
Information you provide to us
You may provide us with information by filling in forms on our Website(s) or by corresponding with us by phone, e-mail, live-chat or otherwise. This includes information you provide when you register for a demo and when you report a problem with our Website.
The personal information you provide may include your name, e-mail address and phone number. By providing us with this information, you expressly consent to our use of your personal information in accordance with this privacy policy.
Information we collect
When you visit our Website we may automatically collect information about your computer, including your IP address, your device, operating system and browser type. We also collect information about your visit, your browsing history, and how you use our Website. This information may be combined with other information you provide to us, as described above.
Appsumer will reach out to Prospects using information provided via the Website or information that is readily available in the public domain, with whom we have a legitimate interest, in order to provide Sales and Marketing information in line with Recital 47 of the General Data Protection Regulation 2018.
How we use your Personal Identifiable Information (PII)
We use personal information about you in connection with the following purposes:
- Fulfilling your requests:
- For a demo of the Appsumer Platform
- For Appsumer content
- To contact you
- Marketing:
- To provide you with information about our services
- We operate an email mailing list program, used to inform subscribers about products, services and/or news we supply/publish. Users can subscribe through an online automated process where they have given their explicit permission. Subscriber personal details are collected, processed, managed and stored in accordance with the regulations named in ‘The policy’ above. Subscribers can manage their preferences using the link in the footer emails sent via our email service provider.
- Email marketing messages may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of subscriber data relating to engagement, geographic, demographics and already stored subscriber data.
- Service Improvements and account management:
- to ensure that content from our Website is presented in the most effective manner for you and for your computer.
Who has access to your information?
- We will never share, sell, or pass on, your personal data to other companies for marketing purposes.
- We use third parties’ analytics technologies. This involves cookies being set via our Website, which then collect information about your usage of our Website.
- Social Media plugins – Pages on our Website contain links to share our content on social networks. By clicking on these ‘share’ links, you enable the social media to know you’ve visited our Website. Please refer to their privacy documents to know what data they collect, for what purpose, and how they use it.
External Website Links & Third Parties
Although we only look to include quality, safe and relevant external links, users are advised to adopt a policy of caution before clicking any external web links mentioned throughout this Website. We cannot guarantee or verify the contents of any externally linked website despite our best efforts. Users should therefore note they click on external links at their own risk and we cannot be held liable for any damages or implications caused by visiting any external links mentioned.
SECTION 2: CLIENTS, END USERS & CLIENTS’ USERS
This section describes what information is collected by Appsumer from Clients, End Users and Clients’ Users and how that information is used by Appsumer.
This section expands upon section 1 and further highlights our policies as pertinent to those categories of users highlighted above.
How do we collect information from End Users?
Information End Users provide to us
When an account is set up (whether by the Client, other End users or by Appsumer) for End Users to access and use the Appsumer Platform, we collect and store certain pieces of PII, including:
- Full name
- Email address
- Telephone number
- Address
By providing us with this information, you expressly consent to our use of your personal information in accordance with this privacy policy.
Information we collect about End Users
We collect and store information about when and how an End User uses the Appsumer Platform, including (but not limited to) activity data, location data, weblogs and other communication data, and the resources and functions of the Service that the Client uses.
All of this information may be combined with other information you provide to us, as described above.
How we use End User Personal Information
We use information collected from End Users to perform our obligations under the Agreement. We also use the Personal Information about End Users in order for effective Service Improvements and account management:
- To ensure that content from the Appsumer Platform is presented in the most effective manner for you and for your computer.
- To contact you in order to help them with their use of the Service
- To track devices, location, active end users, End User engagement, feature usage and End User behaviour tracking to better understand your usage of the Appsumer Platform.
- To communicate with you on important updates to the Appsumer Platform under our obligations in our Agreement to deliver the Service. As per our Terms & Conditions, End Users are unable to opt-out of receiving these emails.
- To send you marketing emails from time to time that we believe are of interest to you. The content is typically industry news and Appsumer news and opinion. For more information see Section 1: How we use your Personal Identifiable Information (PII). End Users can manage their email marketing preferences at any time using the links in each email footer.
Who has access to End User Personal Information?
- We use third parties’ analytics technologies. This involves cookies being set via the Platform, which then collect information about your usage of our Platform.
- All third parties’ analytics technologies with whom we share data are required to be GDPR compliant and process the data in a manner that equally ensures security.
- We will never sell, or pass on, your personal data to other companies for marketing purposes.
- Additionally:
- We may disclose your Personal Data to any member of our group of companies.
- In the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets.
- If Appsumer or substantially all of its assets are acquired by a third party, in which case Personal Data held by us will be one of the transferred assets.
- If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce the Agreement or any other agreements; or to protect the rights, property, or safety of Appsumer, our Clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Updating End User information
End Users can edit any of their information within the Appsumer Platform. It is their responsibility:
- To protect against unauthorised access to their details and the Appsumer Platform.
- To log-off from the Appsumer Platform when not using it.
- To keep their login credentials secret.
How do we collect information from Clients?
Information Clients provide to us
Clients will provide sensitive information including but not limited to:
- Company details, e.g. Address, Bank details
- End User usage data
- Data source access credentials
- Advertising performance related data as well as other performance-related statistics, both directly from Clients as well as through automated data feeds
How we use Client information
We use information collected from Clients to perform our obligations under the Agreement.
Appsumer uses aggregated End User data in order to generate reports of usage and insights for customer support.
Data source credentials and the Clients’ advertising performance data are used to provide the Service and perform obligations under the Agreement.
Appsumer will also create unintelligible data sets using aggregated, pseudonymized and obfusticated advertising performance data. The result of this is anonymised information which:
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- Help us improve the services that Appsumer provides to its Clients, including by improving the forecast algorithms forming part of the Service.
- Generate anonymised aggregated data sets which are used in the form of benchmarking, forecasting and other such reports that are made available for the wider industry and across the Platform.
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Who has access to Client information?
Although aggregated, anonymised data can be made available, as above, only Clients and End Users of the Client have access to their information.
Updating Client information
Where Client Account details (Bank Accounts, Addresses, etc) are required to be amended, please contact your Customer Success representative.
Do we collect Personally Identifiable Information from Clients’ Users?
The Appsumer Platform is based on aggregated performance data and we do not knowingly collect or store any Personally Identifiable Information of the Clients’ Users as part of these activities.
Where Clients’ Users data that contains Personally Identifiable Information, has been inadvertently uploaded to our system by Data Controllers and stored, Appsumer will remove such information within 7 working days of it being brought to our attention.
SECTION 3: GENERAL
Where do we store the Personally Identifiable Information?
The information that we collect from you may be transferred to, and stored at, various destinations, either within the European Economic Area (“EEA”) or outside where some third parties tools, e.g Email Service Providers, are based. Appsumer is the Data Controller in these instances and only works with GDPR and Privacy Shield compliant tools.
Interfaces to data are provided via web portals and as such are globally accessible. Actions on data may be processed by staff who work for us or for one of our hosting, connectivity or telecommunications service providers operating at various locations both within the EEA and outside of the EEA.
By providing us with your information (including Personal Data), you agree to this transfer, storing and processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice.
Cookies
The Appsumer Website and Appsumer Platform use cookies to better the user’s experience.
What are cookies?
Cookies are small text files that are stored by the browser (for example, Internet Explorer or Safari) on your computer or mobile phone. They allow websites to store things like user preferences. You can think of cookies as providing a ‘memory’ for the website, so that it can recognise you when you come back and respond appropriately.
How we use cookies
We can obtain information about your general internet usage by setting a cookie file which is stored on your browser or the hard drive of your Device. We use both session ID cookies and persistent cookies.
Why we use cookies
Session cookies
We use session cookies to make it easier for you to navigate our site. A session ID cookie expires when you close your browser.
Persistent cookies
Persistent cookies enable us to track and target your interests to enhance your experience on our Website. For example, we use this data to understand how you interact with our Website so we can make improvements to the information and design of our Website. Some of these cookies are generated by third parties. An example of this would be anonymous analytics cookies from companies like Google Analytics and conversion tracking pixels from sites on which we run advertising like Google AdWords.
Unless you have adjusted your browser setting so that it will refuse cookies, we will drop cookies onto your Device as soon as you visit our Website and Platform.
How do I turn cookies off?
A persistent cookie remains on the hard drive of your Device for an extended period of time. You can remove persistent cookies via your browser’s “clear cookies” function. Please see www.allaboutcookies.org for more information about blocking cookies on your particular web browser.
Transmission of Information
Appsumer uses SSL (Secure Sockets Layer) as the standard security technology for establishing an encrypted link between a web browser and our Platform. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your information transmitted to our Platform; any transmission is at your own risk. Once we have received your information, we use strict procedures and security features to try to prevent unauthorised access.
Contact & communication with us
Users contacting this us through this website do so at their own discretion and provide any such personal details requested at their own risk. Your personal information is kept private and stored securely until a time it is no longer required or has no use.
Where we have clearly stated and made you aware of the fact, and where you have given your express permission, we may use your details to send you products/services information. This is done in accordance with the regulations named in ‘The policy’ above.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Notice at any time, so please review it frequently. Your continued use of this Website after we make changes is deemed to be acceptance of those changes. If we make material changes to this Notice, we will send an email to all Clients.
Google User Data
How we use End User Google data
When you connect the Appsumer Platform to a Google API, the Appsumer Platform can access your data available on the Google product corresponding to the linked Google API as it is permitted by the API we use.
- Google Ads: when you connect the Appsumer Platform to Google Ads, you grant the Appsumer Platform the ability to read, edit, and delete your campaigns via the Google Ads API (note: we only use the connection to read your stats and don’t perform edit and delete actions) for the customer ids you specify on the Appsumer Platform.
- Google Sheets: when you connect the Appsumer Platform to Google Sheets, you grant the Appsumer Platform the ability to read data via the Google Sheets API for the Sheets you specify on the Appsumer Platform.
- Google Analytics: when you connect the Appsumer Platform to Google Analytics, you grant the Appsumer Platform the ability to read data via the Google Analytics API for the views you specify on the Appsumer Platform.
How we store or share End User Google data
- End User Google Data will not be shared with 3rd parties
- End User Google Data is stored on Amazon Web Services
You can revoke Appsumer’s access to your Google data anytime by visiting your Google Account and revoking Appsumer’s permissions.
Your rights
You have certain rights under the General Data Protection Regulation 2018, including the right to be told what Personal Data we hold about you on our database.
Access to information
You have certain rights under the General Data Protection Regulation 2018, including the right to be told what Personal Data we hold about you on our database. Should you wish to exercise that right, or have your data completely deleted from our systems, please contact us by post or email at the address below.
The Act gives you the right to access personal information held about you by Appsumer Ltd. Your right of access can be exercised in accordance with the Act.
The right to rectification
As a Data subject, you can have your personal data rectified if it is inaccurate or incomplete.
Rectification of End Users Personally Identifiable Information held on the Appsumer Platform, can be done via the Appsumer Platform.
Whereby Personally Identifiable Information is rectified on the Appsumer Platform for End Users, then these changes are made in real-time. For all other requests, Appsumer will comply with any request to rectify information within one month of receipt.
If required, all Appsumer Platform held information change requests can be made via your Customer Success Team or using the address below.
For Client sensitive information changes, please contact finance@appsumer.io.
For all other Data Subjects (Visitors and Prospects), Appsumer will comply with any request to rectify information within one month of receipt. Requests should be sent to the address below.
The right to be forgotten
As a Data subject, you can have your personal data completely removed from all Appsumer systems.
Removal of End Users held on the Appsumer Platform, cannot be undertaken whilst the Client associated with that End User is under contractual obligations with Appsumer.
End Users, who have left the employment or no longer require access to the Appsumer Platform, will have their Personally Identifiable Information completely removed within 7 working days of The Client Success Team receiving notification from The Client.
Whereby the contractual obligations between the Client and Appsumer cease to exist, Appsumer will only hold onto Personally Identifiable Information contained within documentation that is legally necessary for as long as required by law. Personally Identifiable Information will be removed from the Appsumer Platform. Personally Identifiable Information will continue to be held in the marketing databases until such time as the End User opts out.
For all other Data Subjects (Visitors and Prospects), Appsumer will comply with any request to rectify information within one month of receipt. Requests should be sent to the address below.
Data Protection Service
You can obtain further information about data protection and privacy laws by visiting the Information Commissioner’s website at: https://ico.org.uk/for-thepublic/.
The Information Commissioner (ICO) is the UK Supervisory Authority, and should you wish to lodge a complaint with them at any time in respect of how Appsumer is processing your personal data, you can contact them using the following methods:
Website: https://ico.org.uk/concerns/
Live chat: https://ico.org.uk/global/contact-us/live-chat
Phone: 0303 123 1113
Contacting Appsumer
As per the General Data Protection Regulation 2018, Appsumer are Data Processors for our Clients, who are the Data Controllers of their Users data. To this end, Data Subjects of our Clients should address their requests to our Clients directly.
If you have any questions about this Privacy Notice, our practices, or your dealings with Appsumer, you can contact us on privacy@appsumer.io or mail us at:
Data Protection Officer
Appsumer Ltd
3rd Floor
43 Whitfield St
London
W1T 4HD
Your Consent
By agreeing to the terms of this Privacy Notice, you consent to the cookies referenced above being set on your Device.