Privacy Policy

PRIVACY POLICY

Effective Date: January 21st, 2025. 

  1. Introduction.

This Privacy Policy describes Company’s practices regarding information we collect about you and the choices available to you regarding such information. For purposes of this Privacy Policy, unless otherwise stated, “information” or “personal information” means information relating to an identified or identifiable individual.

This Privacy Policy applies to information we collect where we control the purposes and means of processing, specifically information we collect through any of our websites, apps, emails, or advertisements other online services that link to this Privacy Policy (the “Service”) or other sources identified below. Please note that your use of the Service is subject to our Terms of Service.

This Privacy Policy is not intended to amend, revise, or supersede the content license agreements we maintain with clients. It does not apply to data of our asset management and similar clients, including those under content license agreement.

This Privacy Policy does not apply to:

  • the practices of third parties we do not control
  • information processed by us on behalf of our clients
  • information collected in the context of your job application or employment with us

information that has been anonymized or, to the extent permitted by law, deidentified

For our contact details, see the Contact Us section below.

  • Collection.

This section describes the information we collect and how we collect it.

Information You Provide through the Service.

When you use the Service, you may be asked to provide information to us, such as when you create an account, sign up for our loyalty programs, participate in a promotion, respond to our surveys, or contact support. The categories of information we collect in this context include:

  • Contact Identifiers, including your name, email address, and zip code.
  • Characteristics or demographics, including your age, gender, and country.
  • Commercial or transactions information, including records of products or services you purchased, obtained, or considered.
  • Account credentials, including your username, email, and other information for authentication or account access.
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  • Content, including content within any messages you send to us (such as feedback, questions, or survey responses).

Please do not provide any information that we do not request.

Information from Your Browser or Device.

When you use the Service, we and third parties we work with automatically collect information from your browser or device. The categories of information we automatically collect in this context include:

  • Device identifiers, including your device’s IP address and Ad ID.
  • Device information, including your device’s operating software and browser (e.g., type, version, and configuration), internet service provider, and regional and language settings.
  • Internet activity, including information about your browsing history and interactions, such as the features you use, pages you visit, content you view, time of day you browse, and referring and exiting pages.
  • Non-precise location data, such as location derived from an IP address or data that indicates a city or postal code level.

This information is automatically collected through cookies and other tracking technologies incorporated into our Service, as described below:

  • Pixels. Pixels (also known as web beacons) are code embedded in a service. There are various types of pixels, including image pixels (which are one-pixel transparent images) and JavaScript pixels (which contain JavaScript code). Pixels are often used in conjunction with cookies. When you access a service that contains a pixel, the pixel may permit us or a third party to collect information from your browser or device, or to drop or read cookies on your browser. App technologies. App technologies are technologies included in apps that are not browser-based like cookies. For example, our apps may include Software Development Kits (SDKs), which are tools released by third parties that provide certain functionality. When you access our apps, these technologies may permit us or a third party to collect information from your browser or device.
  • Device fingerprinting. Device fingerprinting is the process of analyzing and combining sets of data from your device, such as JavaScript objects and installed fonts, to create a “fingerprint” and uniquely identify your browser or device.

We use these tracking technologies for a variety of purposes, including to help make our Service work, personalize your browsing experience, prevent fraud and assist with security, perform measurement and analytics, and provide advertising (including targeted advertising).

To exercise choice around tracking technologies, see Your Privacy Choices below.

Information from Other Sources.

We also collect information from other sources. The categories of other sources from which we collect information include:

  • Business partners that offer co-branded services, sell or distribute our products, or engage in joint marketing or promotional activities.
  • Third party vendors and related parties we work with in connection with receiving analytics, advertising, security, and fraud prevention services.
  • Data providers, such as licensors of private and public databases.
  • Public sources, such as information in the public domain.

Information We Infer.

We infer new information from other information we collect, including to generate information about your likely preferences or other characteristics.

Sensitive Information.

Some of the information we collect may be considered sensitive under applicable law. See additional disclosures in your region for details.

  • Purposes for Collection and Use.

Our purposes for collecting and using information include:

  • Providing services. We collect and use information to provide services to you, including to operate the Service, establish and maintain your account, and provide support.
  • Personalizing your experience. We collect and use information to personalize your experience and show you content we believe you will find interesting.
  • Communications. We collect and use information to communicate with you about updates, security alerts, changes to policies, and other transactional messages. We also collect and use information to personalize and deliver marketing communications to you, including by email, and, where you opt-in, push notification.
  • Analytics. We collect and use information to understand trends, usage, and activities, for example through surveys you respond to and tracking technologies that we incorporate into the Service (such as Google Analytics).
  • Advertising. We collect and use information to advertise our products and services. Various third parties such as ad agencies, ad networks, publishers, social media platforms, and technology providers may be involved in this process. For example, we place ads on third party publisher websites and social media platforms. These ads incorporate tracking technologies to help serve the ads, measure their performance, detect ad fraud, limit the frequency of ads shown, and provide insights. If you visit our Service after seeing an ad on a third party service, tracking technologies on our Service help us attribute conversions and determine how effectively we use our ad budgets.

Some of the advertising we engage in may be “targeted advertising,” which is the practice of showing you more relevant or personalized ads based on your activity collected over time and across non-affiliated services. Targeted advertising often involves us incorporating third party tracking technology into our Service or providing (often hashed) contact or device identifiers to a third party, which then matches common factor between our data and their data (or a partner’s data) to serve ads to you or individuals like you. For example, we incorporate the Meta pixel on our website to serve ads to audiences created by Meta based on the data we provide.

  • We also use audience modeling services, where we and a partner each provide (often hashed) data to a technology provider. The technology provider then matches common factors between our and the partner’s data to allow us to gain insights into audience overlap and campaign performance. Promotions. When you voluntarily enter a promotion, we collect and use information as set out in the official rules that govern the promotion as well as for administrative purposes and as required by law. By entering a promotion, you agree to the official rules that govern that promotion, and that, except where prohibited by applicable law, we, the sponsor, and related entities may use your name, voice and/or likeness in advertising or marketing materials.
  • Improvements. We collect and use information to develop and improve our services.
  • Security and enforcement. We collect and use information to prevent, detect, investigate, and address fraud, breach of policies or terms, or threats or harm.
  • At your direction or with your consent. We collect and use information for additional purposes where you direct us to use it in a certain way or with notice to you and your consent.
  • Non-personal information. Sometimes we anonymize or deidentify information so it is no longer considered personal information under applicable law. Where we deidentify information, we commit to maintain and use the deidentified information in deidentified form and not attempt to reidentify it. We may use non-personal information for any purpose to the extent permitted by applicable law.

To exercise choice around our collection and use, see Your Privacy Choices below.

  • Disclosure.

We disclose the information we collect for the purposes described in this Privacy Policy. The categories of persons to whom we disclose information include:

  • Service providers. Many of the third parties we work are service providers that collect and process information on our behalf. Service providers perform services for us such as payment processing, data analytics, marketing and advertising, website hosting, and technical support. To the extent required by law, we contractually prohibit our service providers from processing information they collect on our behalf for purposes other than performing services for us, although we may permit them to use non-personal information for any purpose to the extent permitted by applicable law.
  • Third party vendors and related parties. Some of the third parties we work with independently control the purposes and means of processing your information. For example, we disclose information to ad networks, technology providers, and other third parties that help provide targeted advertising. For these third parties, we encourage you to familiarize yourself with and consult their policies and terms of use.
  • Business partners. We disclose information to our business partners in connection with offering co-branded services, selling or distributing our products, or engaging in joint marketing or promotional activities.
  • Affiliates. We disclose information to our affiliates and related entities, including where they act as our service providers subject to this Privacy Policy or use the information in accordance with their own privacy policies.
  • The public. We disclose information you make public, such as information in your profile or that you post on public boards. Please think carefully before making information public as you are solely responsible for any information you make public. Once you have posted information, you may not be able to edit or delete such information, subject to any rights you have under applicable law.
  • Recipients in a merger or acquisition. We disclose information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
  • Recipients for security and enforcement. We disclose information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also disclose information to protect the rights, property, life, health, security and safety of us, the Service or anyone else.
  • Recipients at your direction or with your consent. We disclose information where you direct us to or with notice to you and your consent.
  • Non-personal information. We may disclose non-personal information for any purpose to the extent permitted by applicable law.

To exercise choice around our disclosures, see Your Privacy Choices below.

  • Third Parties.

Our Service may link to, or be incorporated into, websites and online services controlled by third parties. In addition, we may integrate technologies into our Service, including those disclosed in the Collection section above, controlled by third parties. Except where third parties act as our service providers, they, and not us, control the purposes and means of processing any information they collect from you, and you should contact them directly to address any concerns you have about their processing. Third party data practices are subject to their own policies and disclosures, including what information they collect, your choices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

  • Processing on behalf of Our Clients.

In connection with providing services to our clients, we collect and use information on their behalf (“client data”). For example, we may collect and process information in order to maintain and administer your accounts, respond to your questions, comply with your requests, market and advertise to you, and otherwise comply with the law. Client data has historically included contact identifiers, characteristics or demographics, commercial or transactions information, device identifiers, device information, internet activity, and non-precise location data, among other information. Our processing of client data as a processor or service provider is governed by the terms of our service agreements with our clients, and not this Privacy Policy. We are not responsible for how our clients treat the information we collect on their behalf, and we recommend you review their privacy policies and terms. In the event we are permitted to process client data for our own purposes, we will process the client data in accordance with the practices described in this Privacy Policy.

  • Your Privacy Choices.

This section describes the choices available to you regarding your information.

Communications.

You can opt-out of receiving certain communications from us as follows:

  • Emails. To stop receiving marketing emails, change your communication preferences through your account settings, follow the unsubscribe instructions near the bottom of such emails, or email us at as set out in the Contact Us section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt out of transactional emails.
  • Push notifications. To stop receiving push notifications, adjust your device settings or uninstall our app.

Accounts.

If you have an account with us, you can delete your account through your account settings. We will address your request in accordance with our data retention practices.

If you have linked your Company account with certain third party services, you may unlink your accounts at any time by visiting your Company account settings. Please note that unlinking your accounts will not affect any information previously disclosed through the linking. We are not responsible for the data practices of any third parties, and we recommend that you carefully review their privacy policies and terms of use.

Browser and Device Controls.

  • Cookies and pixels. Our cookies management module, available here, allows you to control the cookies deployed on our website. You can choose to accept, refuse, or set them specifically as set out in the cookies management module. In addition, you may be able to manage cookies through your browser settings. When you manage cookies, pixels associated with such cookies may also be impacted. Please note that cookie management only applies to our website. If you use multiple browsers, you will need to instruct each browser separately. If you delete or reset your cookies, you will need to reconfigure your settings. Your ability to limit cookies is subject to your browser settings and limitations.
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  • App technologies. Unlike cookies, app technologies cannot be controlled by your browser settings. For some platforms (like Apple iOS), we will only receive access to your device’s Ad ID if you provide consent. You can reset your device’s Ad ID through your device settings, which is designed to limit how the prior Ad ID can be used. See your device settings for details. You can stop all collection of information through an app by uninstalling the app.
  • Preference signals. Your browser or extension may allow you to automatically transmit Do Not Track and other preference signals. Except as required by law, we do not respond to preference signals.
  • Third party opt-out tools. Some third parties we work with offer their own opt-out tools related to information collected through cookies and pixels. To opt out of your information being used by Google Analytics, please visit https://tools.google.com/dlpage/gaoptout. We are not responsible for the effectiveness of their tools.
  • Industry opt-out tools for targeted advertising. Some third parties we work with are part of the National Advertising Initiative or follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising, which offer their own opt-outs tools for targeted advertising. For details, visit https://www.networkadvertising.org/choices/ and https://youradchoices.com/control. We are not responsible for the effectiveness of their tools.
  • Children.

The Service is not directed toward children under 18 years old, and we do not knowingly collect personal information (as that term is defined by the U.S. Children’s Online Privacy Protection Act, or “COPPA”) from children. If you are a parent or guardian and believe we have collected personal information from children, please contact us as set out in the Contact Us section below. We will delete the personal information in accordance with COPPA.

  • Security.

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Please note that transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

  1. Retention.

We retain information for the length of time that is reasonably necessary for the purpose for which it was collected, and as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

  1. International Transfer.

We are based in the U.S. If you are located outside the U.S., please be aware that your information may be transferred to and processed in the U.S. or another country where we operate. Where required by applicable law, we will provide appropriate safeguards for data transfers.

  1. Changes to this Privacy Policy.

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide additional notice to you, such as through email or prominent notice on the Service.

  1. Contact Us.

The controller under this Privacy Policy is:

Apptopia, Inc. (“Company,” “we,” “our,” or “us”)

132 Lincoln St, 3rd Floor, Boston, MA 02111

privacy@apptopia.com

If you have questions about our practices regarding your information or have trouble accessing this Privacy Policy, please contact us at the postal address or email address above. To exercise choice available to you, please use the designated methods listed in this Privacy Policy.