1.1 Appness Pte. Ltd., operatingunder the brand name «xxxx»(“Company”, “APPNESS”, “we”, “us”, “our”), is a mobile advertising company thatprovides its customers with a platform and software to deliver targetedadvertising to their users. Our technology enables our partners to show mobileapplication users more relevant ads based on users’ interests and behaviour,via online services that provide and administer the advertising platform andsoftware owned and operated by APPNESS (the “Services”).
1.2 To provide these Services, we usecertain information about user activity and preferences that we receive fromour supply partners and advertisers (together, the “Advertising Partners”). Weunderstand that such users (“Consumers”) care about their personal informationand how it is used and shared, and we take their privacy very seriously.
1.3 APPNESS also operates a website (https://XXXX.com/, the “Website”) that may collectdata about individuals who visit it and/or perform actions on it (“WebsiteUsers”). In this Privacy Policy, Website Users and Consumers are collectivelyreferred to as “Users”, and together with our Advertising Partners we refer to“you”.
1.4 This Privacy Policy is designedto explain to Users and Advertising Partners how we collect, use, share, secureand otherwise process personal information when you use the Website or theServices. Please read it carefully to understand our practices regarding thepersonally identifiable information we gather when Users access the Website oruse our Services (“Personal Information”) and how we will treat it.
1.5 Because we cannot deliver theServices without processing User Personal Information, if you do not agree withour policies and practices, your choice is not to use our Website or Services.By using the Website or the Services in any manner, you acknowledge that youaccept the privacy practices and policies described in this Privacy Policy andconsent to our collection, use and sharing of your information as set out here.We may update this Policy from time to time; your continued use of the Website orServices after we make changes will be deemed acceptance of those changes, soplease review this Policy periodically for updates.
1.6 Any capitalised terms used butnot defined in this Privacy Policy have the meaning given to them in theCompany Terms of Use. APPNESS voluntarily commits to comply with the EU GeneralData Protection Regulation (GDPR).
2.1 This Privacy Policy applies tothe Website and the Services. It describes how APPNESS collects, uses,discloses and secures the Personal Information of Users, as well as yourchoices regarding the use, access and correction of your Personal Information.
2.2 This Policy does not apply to thepractices of companies that we do not own or control, or to individuals whom wedo not employ or manage.
2.3 In particular, this PrivacyPolicy covers:
· Theinformation APPNESS collects or receives;
· HowAPPNESS uses this information; and
· Youroptions to opt out of certain practices or to dispute such practices.
3.1 Through the Services and theWebsite, APPNESS collects two main types of information: Personal Informationand anonymous information; we may also generate a third category, aggregateinformation. Depending on how you interact with us, we may receive informationfrom our Advertising Partners, automatically collect information, and/orreceive information that Website Users voluntarily provide. We may also obtaininformation from other trusted sources to update or supplement information thatWebsite Users voluntarily provide or that we automatically collect or receivefrom Advertising Partners.
3.2 User Data Supplementation
We may receive information about Users from other sources, including publiclyavailable databases or third parties from whom we purchase data, and combine itwith the information we already have about Users. This helps us update, expandand analyse our records, identify new customers, deliver marketing services andprovide products and services that may be of interest to you. If you provide uswith Personal Information about others, or if others give us your PersonalInformation, we will use that Personal Information only for the specificpurpose for which it was provided.
3.3 Examples of Personal Informationwe may obtain from public sources or purchase from third parties and combinewith information we already have include marketing data that is combined withdata we receive from Advertising Partners to create more tailored advertisingand products.
4.1 If you are a Website User,APPNESS may collect the following categories of Personal Information from you:
· ThePersonal Information you provide via the contact form on the Website, such asyour name, email address, company name and any other information you choose tosubmit.
· Informationyou provide when you communicate with us by email or other channels, includingwhen you sign up for updates or marketing communications.
4.2 If you have given us a way tocontact you, we may use that information to communicate with you. For example,we may:
· Sendyou promotional offers on behalf of other businesses;
· Contactyou about your use of the Services; or
· Sendyou service-related or legal notices.
4.3 We may receive a confirmationwhen you open an email from us, which helps us improve the relevance of ourcommunications and Services. If you do not want to receive marketingcommunications from us, you can unsubscribe by clicking “UNSUBSCRIBE” in anymarketing email or by emailing us at privacy@appness.com. Please note that even if you optout of marketing, you may still receive important legal or service-relatednotices, and you are responsible for reviewing such notices for changes.
4.4 Information collected automatically on the Website
We may also collect certain information automatically through cookies andsimilar tracking technologies. For example, we use Google Tag Manager (throughwhich LinkedIn Insight Tag, META pixel, X website pixel are installed). Theinformation collected in this way may include IP address, browser type,Internet service provider, referring/exit pages, files viewed on our Website(e.g., HTML pages, graphics), operating system, date/time stamp and clickstreamdata, which we may use in aggregate form to analyse trends.
4.5 As stated in the policy, we donot retain or use any information collected automatically on the Websitethrough cookies or similar technologies.
4.6 Cookies and Tracking Technologies
Our Advertising Partners may use cookies or similar technologies to analysetrends, track User movements around the Website and gather demographicinformation about our User base as a whole. Cookies are small text files placedon your device by websites you visit; they are widely used to make websiteswork or work more efficiently, as well as to provide information to siteowners.
4.7 You can usually control cookiesat the browser level; however, disabling cookies may limit your ability to usecertain features or functions on our Website or Services. To learn more aboutcookies, including how to see which cookies have been set and how to manage ordelete them, please visit www.aboutcookies.org.
4.8 APPNESS does not retain or useany information collected automatically on the Website through cookies orsimilar technologies.
5.1 “Consumers” are individuals whodownload, use or otherwise interact with applications and/or websites ofAPPNESS’s Advertising Partners and/or third parties that work directly with appdevelopers.
5.2 If you are a Consumer who uses orinteracts with the Services, APPNESS may receive non‑sensitive PersonalInformation about you from our Advertising Partners, which may include:
· IPaddress;
· AndroidID or mobile advertising identifiers (such as GAID/IDFA);
· Post‑backdata shared with APPNESS, for example: ISP, country, region, city, metro code,application name, application version, a limited number of in‑app events, anddevice information (make, model, OS, OS version, language, device type), aswell as connection information. This post‑back data is considered User PersonalInformation only when it is processed together with the respective User’sIDFA/GAID.
5.3 By using an Advertising Partner’sapplication, you grant that application developer permission to collectPersonal Information and share it with us under our agreement with thatAdvertising Partner. We may also combine such Personal Information with anonymousinformation from other sources in order to deliver advertisements through theServices.
5.4 In the event of a data breach,Advertising Partners and Website Users will be notified without undue delay.
6.1 Advertising Partners
We work with advertising exchanges and other partners to deliver interest‑basedadvertising within mobile applications. These partners may use your mobileadvertising identifier (such as Apple’s IDFA or Google’s Advertising ID), alongwith contextual signals, to show ads that are more relevant to your interests.
6.2 The Services may contain links tothird‑party websites, non‑APPNESS apps or other third‑party content. We cannotcontrol how such third parties treat User Personal Information, and theirprivacy practices are likely to differ from those described in this Policy. Ifyou choose to engage in any transaction or service related to another websiteor business, please review that website’s or business’s own policies.
6.3 If you are a Consumer, pleasenote that APPNESS receives your Personal Information from its AdvertisingPartners and does not have a direct relationship with you. If you no longerwish to be contacted by one of APPNESS’s Advertising Partners, you shouldcontact that Advertising Partner directly. You may also contact us at privacy@appness.com and we will do our best to assistyou.
6.4 APPNESS may work with Google andother providers to deliver the best advertising opportunities to its clients.Data subjects can refer to Google’s own policies to learn more about how Googleprocesses data, including its use of remarketing tags (see https://policies.google.com/technologies/partner-sites for more information about Google’spartners).
6.5 Service Providers
We may engage third‑party companies and individuals to perform tasks on ourbehalf, such as providing computing and network infrastructure services, andmay need to share User information with them in order to provide the Services.Unless we state otherwise, these agents do not have any right to use thePersonal Information we share with them beyond what is necessary to assist us.
7.1 Website User Personal Information
We use the Personal Information we collect about Website Users to сommunicate with them about their use of the Website or the Services
7.2 Consumer Personal Information
We use the information we receive about Consumers primarily to provide andimprove the Services and to better understand which products and services mayinterest Consumers. For example, APPNESS may use Consumer Personal Informationto:
· Operate,manage and enhance the Services;
· Performthe Services for our Advertising Partners;
· Analysehow Users make use of the Services.
8.1 APPNESS has implemented measuresdesigned to protect User Personal Information from accidental loss and fromunauthorised access, use, alteration and disclosure. The security of yourinformation also depends on you: where we have given you (or where you havechosen) a password for access to certain parts of the Website, you areresponsible for keeping this password confidential and not sharing it withanyone.
8.2 APPNESS does not rent or sellUser Personal Information in personally identifiable form to any third party.
8.3 Legal Notice
We may disclose your Personal Information as required by law, for example tocomply with a subpoena or other legal process, or when we believe in good faiththat disclosure is necessary to protect our rights, your safety or the safetyof others, to investigate fraud, or to respond to a governmental request.
8.4 If APPNESS is involved in amerger, acquisition or sale of all or substantially all of its assets, we willinform you via email and/or a prominent notice on our Website of any change inownership, uses of your Personal Information and any choices you may haveregarding your Personal Information. We may also disclose your PersonalInformation to other third parties with your prior consent.
8.5 Cross‑Border Data Transfers
APPNESS operates globally and may transfer, store or process PersonalInformation in jurisdictions outside your country of residence, includinglocations where data protection laws may differ from those in your homecountry.
· For residents of Singapore,your Personal Information may be processed in Singapore and may also betransferred and stored outside Singapore in accordance with the Personal DataProtection Act 2012 of Singapore (PDPA) and other applicable Singapore data protectionlaws, with appropriate safeguards in place.
· Forresidents of Quebec (Canada), your Personal Information may be transferred andstored outside of Quebec in accordance with the Act Respecting the Protectionof Personal Information in the Private Sector (Quebec Private Sector Act).
· Forresidents of Canada (outside Quebec), your Personal Information may betransferred outside Canada, and we take steps to ensure such transfers complywith applicable privacy laws.
· Forresidents of the European Economic Area (EEA), the United Kingdom andSwitzerland, we comply with the GDPR and applicable UK data protection laws;when we transfer data outside these regions, we implement safeguards such asStandard Contractual Clauses or rely on other legally recognised mechanisms.
· Forresidents of Brazil, we process and transfer personal information in accordancewith the Lei Geral de Proteção de Dados (LGPD) and ensure adequate mechanismsare in place when data is transferred outside Brazil.
· Forresidents of California (USA), we may share or transfer personal information incompliance with the California Consumer Privacy Act (CCPA) and the CaliforniaPrivacy Rights Act (CPRA); you may have specific rights under these laws.
· Forresidents of Australia, we comply with the Australian Privacy Act 1988(including APP 8) and ensure that international transfers follow establishedprivacy principles.
· Forother jurisdictions with data transfer requirements (including South Korea,Japan and other regions with similar laws), we take reasonable steps to ensurethat personal information is processed in compliance with local regulations.
8.6 Whenever we transfer PersonalInformation outside your province, territory or country, we do so in line withthis Privacy Policy and applicable data protection laws, using appropriatesafeguards such as contractual clauses, data transfer agreements or other legalmechanisms. If you have questions about our data transfer practices orsafeguards, you may contact us at privacy@appness.com.
9.1 To opt out of interest‑basedadvertising from APPNESS, you can email us at privacy@appness.com. In order for us to process yourrequest, your email must include your advertising ID (e.g., IDFA/GAID/otherrelevant identifier); if your email does not contain this information, we willnot be able to complete your opt‑out request.
9.2 You may also opt out ofpersonalised advertising by:
· Adjustingyour device settings to limit ad tracking or reset your advertising ID (seeyour iOS or Android settings for instructions);
· Usingindustry opt‑out tools such as YourAdChoices (for US users) orYourOnlineChoices (for EU users).
9.3 Opting out means that ads you seefrom us will not be tailored based on behavioural data, but you may stillreceive content and advertising. You can control how your browser responds tocookies by changing your browser’s privacy and security settings, and you mayopt out of certain cookies and browser‑enabled interest‑based advertising.Please note that:
· Theseopt‑outs apply only to interest‑based advertising;
· Websitesmay still collect information for other purposes;
· Opt‑outchoices are stored in cookies in each browser you use, so you must repeat themfor other browsers and devices; and
· Deletingcookies may remove your opt‑out preferences, so you should revisit the relevantopt‑out sites periodically.
9.4 Advertising Partners may alsoprovide mechanisms for you to opt out of or limit their collection ofinformation. We are not responsible for the privacy practices of ourAdvertising Partners or other third parties.
10.1 Security
We follow generally accepted standards to protect User Personal Informationsubmitted to us, both during transmission and once received. If you havequestions about security, you can contact us at privacy@appness.com.
10.2 Accessand Correction – Website Users
If you are a Website User, APPNESS will, upon request, inform you whether itholds any of your Personal Information. You may access, correct or requestdeletion of your Personal Information by contacting us at privacy@appness.com; we will respond within a reasonabletimeframe.
10.3 Access and Correction – Consumers
APPNESS acknowledges that Consumers also have the right to access theirPersonal Information, but we have no direct relationship with Consumers.Individuals who wish to access, correct, amend or delete inaccurate data shouldcontact the relevant Advertising Partner. If we are asked to remove data, wewill respond within a reasonable timeframe; you may also contact us at privacy@appness.com and we will do our best to assist.
DataRetention
10.4. APPNESS will retain your information for as long as needed to provide theServices, comply with legal obligations, resolve disputes and enforceagreements. As noted earlier, APPNESS does not retain or use any informationcollected automatically on the Website through cookies or similar technologies.
10.5 The person responsible forprivacy issues at APPNESS is IvanIvanov (ivan@appness.com). Please include your name, addressand email address in any correspondence so we can respond promptly.
11.1 If Users are based in theEuropean Union, APPNESS may process their Personal Information in countriesoutside the European Economic Area (including Singapore). Some of thesecountries may not provide the same level of data protection as countries withinthe EEA, but APPNESS’s collection, storage and use of Personal Information willcontinue to be governed by this Privacy Policy and applicable laws.
11.2 Where a country in whichprocessing occurs is not considered to offer an adequate level of protectionunder an EU adequacy decision, User Personal Information is transferred basedon Standard Contractual Clauses or other appropriate safeguards between APPNESSand the relevant Advertising Partner.
12.CHILDREN’S PRIVACY
12.1 APPNESS does not knowinglycollect or solicit Personal Information from anyone under the age of 13..
12.2 If we learn that we havecollected Personal Information from a child under 13, we will delete thatinformation as quickly as possible. If you believe we may have information fromor about a child under 13, please contact us at privacy@appness.com.
13.1 Because APPNESS is committed toprotecting User privacy as described in this Policy, if you believe we are notcomplying with this Policy, or if you have any questions or wish to take anyother action concerning this Policy or your Personal Information, we encourageyou to contact us at privacy@appness.com. We will investigate your complaint,take appropriate action and report back to you within 45 days.
13.2 Under certain conditions, if youare not satisfied with the above dispute resolution mechanism, you may be ableto invoke binding arbitration.
14.1 We may update this PrivacyPolicy from time to time to reflect changes in our information practices. Weencourage you to review this page periodically for the latest information onour privacy practices.
15.1 If you believe we are notcomplying with this Policy, have questions, or wish to exercise any rightsconcerning this Policy or your Personal Information, please contact us at privacy@appness.com. We will investigate your inquiry,take appropriate action and respond within 45 days.