AppOnboard Privacy Policy

Effective as of November 30, 2018

Introduction

AppOnboard, Inc. respects your privacy. This Privacy Policy describes how and why we collect, use, disclose, store and otherwise process your personal data through our AppOnboard website, software development kits (SDKs), application programming interfaces (APIs), and other related services (the “AppOnboard Services”).

Who We Are

AppOnboard provides technology services that allow publishers of mobile applications (“Apps”) to create playable demos of their Apps.

AppOnboard’s Services allow publishers to display these demos within an App store, such as the Google Play Store for Android users. When our playable demos (“App Store Playable Demos”) are displayed by publishers, users can try out Apps before purchasing or downloading them to determine whether the App is of interest.

AppOnboard’s Services also allow publishers to show their demos as advertisements within other Apps as part of an advertising network offered by AppOnboard (“Playable Advertisements”). These Playable Advertisements allow the creators of the advertised Apps to reach audiences that may be interested in their Apps. These ads also allow the publishers of the Apps that host the ads to generate revenue, enabling these publishers to reduce charges for their Apps or offer them for free.

AppOnboard’s collection and use of your personal data varies based on how you interact with our Services. In order to help you find the information in this Policy that is most relevant to you, you should navigate to the sections that describe how you interact with AppOnboard and the AppOnboard Services.

How and Why We Use Personal Data

App Store Playable Demos

The Information We Collect

When you interact with an App Store Playable Demo, we collect information about your device and the demo you view or interact with. Generally, the AppOnboard Services do not collect information that identifies you directly (for example, we do not collect information such as your name, user name, email address, or a mailing address). We will not combine this information with any information that identifies you without your express consent.  

When you interact with an App Store Playable Demo, we collect:

  • Information about your device such as the type and model, manufacturer, operating system version (e.g., Android Pie 9.0), device language setting, carrier name, IP address, mobile browser, and identifiers assigned to your device, such as its Android Advertising ID.
  • Information about your visit, including session start/stop time, time zone, and network connection type (e.g., WiFi, cellular).
  • Information about how you interact with the demo such as whether you interacted with it, where and how you clicked on it (e.g., tap vs. swipe), and what elements or features of the ad you clicked on or otherwise interacted with.
How We Use the Information We Collect

We use the information we collect from App Store Playable Demos for the following purposes:

  • To provide, maintain, secure, and improve the AppOnboard Services and to develop new services;
  • To identify and prevent improper or fraudulent behavior; and,
  • To allow publishers to determine the effectiveness of their App Store Playable Demos on App purchases or downloads.

In some cases, for certain purposes, your consent may be required prior to collecting or using your data for these purposes. In those cases, we will obtain consent directly from you before using the information for that purpose.

How We Share the Information We Collect

AppOnboard may share the data we collect from App Store Playable Demos with certain third parties for lawful purposes. Generally, we share this data in an aggregated or de-identified format. We do not share device-level data unless directed to do so by the controller of the data (usually the publisher of the Playable Demo) or as required by law.

Sharing with Publishers of the Demo App

AppOnboard may share aggregate information collected from App Store Playable Demos with the publishers of the App in the Demo, such as how End Users interacted with their demos. We share this information with them for reporting purposes and so that they can improve their products, services, and the demos they publish through the AppOnboardServices.

AppOnboard does not share device-level data with the publisher unless the publisher, in its role as the controller of the data, directs us to do so for the sole purpose of evaluating the performance of the Playable Demo. This data generally does not identify you directly.

Sharing with Service Providers

We may sometimes use other businesses (“Service Providers”) to perform certain services for us or on our behalf, such as analytics, messaging, payment processing, hosting and maintenance, and data storage and management services. We provide our Service Providers with the information reasonably necessary for them to perform the services on our behalf.  Each Service Provider must agree to implement and maintain reasonable security procedures and practices appropriate to the nature of the information involved in order to protect your information from unauthorized access, destruction, use, modification or disclosure.

Other Legal Purposes

AppOnboard may access, preserve, and disclose any information we have collected about you or that you have submitted to us as required for legal purposes, including:

  • In response to subpoenas, court orders, or legal process, or to establish, protect or exercise our legal rights or defend against legal claims;
  • To protect the rights and property of AppOnboard, Business Partners (including advertisers and publishers), our licensors, or the public;
  • If we believe it is necessary in order to investigate, prevent or take action regarding illegal activities, fraud, or violations of the personal or intellectual property rights of others or situations involving potential threats to the safety of any person;
  • To our corporate affiliates, joint ventures or other companies under common control with AppOnboard (in which case we will require such entities to honor this Privacy Policy); and,
  • If AppOnboard is acquired by or merged with another entity or in connection with a sale of our assets.

Playable Advertisements in Third-Party Apps

The Information We Collect

When you interact with an App that uses the AppOnboard Services to display Playable Advertisements, we collect information about your device and the ads you view or interact with.  Generally, the AppOnboard Services do not collect information that identifies you directly (for example, we do not collect information such as your name, any user name associated with the App you use, your email address, or a mailing address).  We will not combine this information with any information that identifies you without your express consent.

When you interact with a Playable Advertisement in a third-party App, we collect:

  • Information about your device such as the type and model, manufacturer, operating system (e.g., iOS or Android) and operating system version (e.g., iOS 11.2), device language setting, carrier name, IP address, mobile browser (e.g., Chrome, Safari), applications using the AppOnboard Services and the version of such applications, identifiers assigned to your device, such as its iOS Identifier for Advertising or Android Advertising ID, and the geo-location of your device (using GPS or other geo-location data), when location services have been enabled for the mobile App you are visiting.
  • Information about your visit such as log information, including the App visited, session start/stop time, time zone, and network connection type (e.g., WiFi, cellular).
  • Information about the ads we deliver and how you interact with them such as the type of ad, the placement of the ad, whether you clicked on it, where and how you clicked on it (e.g., tap vs. swipe), what elements or features of the ad you clicked on or otherwise interacted with, and whether you visited the advertiser’s website or downloaded an App of the advertiser.
  • Information from Third Parties that Business Partners and other third parties have collected and share with AppOnboard, such as information they collect through their Apps or other services, which may include general demographic or interest information, if it is lawful for them to share such data with us under applicable privacy laws.
How We Use the Information We Collect

We use the information we collect from Playable Advertisements in order to:

  • Provide, maintain, secure, and improve the AppOnboard Services and to develop new services;
  • Allow publishers to offer ads from our advertisers in their Apps, and to allow advertisers to provide the ads;
  • Calculate appropriate charges for advertisers; and,
  • Identify and prevent improper or fraudulent behavior.
  • In some cases, for certain purposes, your consent may be required prior to collecting or using your data for that purpose. In those cases, we will obtain consent directly from you before using the information for that purpose.
How We Share the Information We Collect

AppOnboard may share the data we collect from Playable Advertisements in third-party Apps with certain third parties for lawful purposes.

Sharing with Advertisers

AppOnboard may share aggregate information collected from Playable Advertisements with the advertiser regarding when and how ads were displayed, how End Users clicked on or interacted with their ads, and how many End Users downloaded their Apps or visited their websites. We share this information with them for reporting purposes, and so that they can improve their products, services, and the advertising they conduct through our Services.

Sharing with App Publishers

AppOnboard may share aggregate information collected from Playable Advertisements with the publishers of the Apps that display the ads, such as when and how ads were shown on their Apps. AppOnboard shares this information for reporting purposes.

Sharing with Attribution Partners

We may share information collected from Playable Advertisements with certain third-party attribution partners designated by advertisers or ad agencies. We may share this information in order to:

  • Verify the authenticity of the interactions that occur with the advertisements we provide;
  • Receive credit for advertiser billable events such as installs of applications;
  • Independently verify performance data such as impressions and button clicks; and,
  • Help prevent fraud, provide security and improve the accuracy of the AppOnboard Services.
Sharing with Other Service Providers

We may sometimes use other businesses (“Service Providers”) to perform certain services for us or on our behalf, such as analytics, messaging, payment processing, hosting and maintenance, and data storage and management services. We provide our Service Providers with the information reasonably necessary for them to perform the services on our behalf.  Each Service Provider must agree to implement and maintain reasonable security procedures and practices appropriate to the nature of the information involved in order to protect your information from unauthorized access, destruction, use, modification or disclosure.

Other Legal Purposes

AppOnboard may access, preserve, and disclose any information we have collected about you or that you have submitted to us as required for legal purposes, including:

  • In response to subpoenas, court orders, or legal process, or to establish, protect or exercise our legal rights or defend against legal claims;
  • To protect the rights and property of AppOnboard, Business Partners (including advertisers and publishers), our licensors, or the public;
  • If we believe it is necessary in order to investigate, prevent or take action regarding illegal activities, fraud, or violations of the personal or intellectual property rights of others or situations involving potential threats to the safety of any person;
  • To our corporate affiliates, joint ventures or other companies under common control with AppOnboard (in which case we will require such entities to honor this Privacy Policy); and,
  • If AppOnboard is acquired by or merged with another entity or in connection with a sale of our assets.

Business Partners and Visitors to the AppOnboard Website

Information you Choose to Submit

You may be asked to provide personal information in certain fields on this Website, such as an email address to sign up for our marketing list. Providing this information is strictly voluntary. If we request that you volunteer personal information on the Website, we will provide an explanation of the purposes and limitations of AppOnboard’s collection and use of that data.

To become a Business Partner, you may be asked to provide certain personal information, including your name, your company name, email address, physical address, phone number, tax identification information, accounting and bank information, and payment information (including credit card information).

We provide Business Partners with tools and/or methods to access or change the information provided to us in association with your account.

Information We Automatically Collect

When you visit and use our Website, we may also automatically collect and use certain data.  We collect information in standard log files that may include your IP address, your Internet Service Provider (ISP), the Web browser you used to visit the Website, the time you visited the Website, which web pages you visited on the Website, and other anonymous usage data.

In addition, we may use a technology called “cookies” and similar identification technologies.  A cookie is a small file transferred to your computer or device that identifies you as a unique user.  We may use cookies to improve the quality of our Website and make it easier to use.  We do this by storing information (for example, settings preferences) about a particular user session in cookies in order to provide you with a seamless experience during your visits.  If you choose to do so, you can configure your browser to delete existing cookies or disable cookies altogether.  However, certain features of the website may not work if you delete or disable cookies.

Google Analytics

This website uses Google Analytics, a web analytics service of Google, Inc. (“Google”). Google Analytics uses cookie text files to analyze how our Website is used. Google uses the data stored on these cookies to compile reports on website activities and to provide further services related to the use of the Website. Google may also transfer this information to third parties if required to do so by law or if third parties process this data on behalf of Google.

You can object to data collection and storage by Google Analytics at any time by downloading and installing a browser deactivation add-on. This prevents Google Analytics from storing and processing data about your website visits. For more information and instructions on how to download and install, see https://tools.google.com/dlpage/gaoptout.

Social Media Plugins

Our Website includes social media features, such as social media plug-ins and links to our social media pages. These links may collect your IP address and which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site.

Your interactions with these features are governed by the privacy policy of the organization providing it and may be determined by whether you are signed into your social media account when you access our Website. For example, if you create or log into your account through a third-party social networking site, we may have access to certain information from that site, such as your name, account information and friends, in accordance with the authorization procedures determined by such third-party social networking site. To prevent this, you should log off of your social media account before navigating to our Website.

The social media providers explain the information obtained by them and how you can limit it on their websites, which you can access at the links below. You can limit or prevent transmitting your data to social media providers by using the tools and methods provided on their respective websites.

Do Not Track

The Website does not respond to web browser “Do Not Track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time.  Visit http://www.donottrack.us to find out more about “Do Not Track.”

How We Use Your Personal Information

If you are an AppOnboard Business Partner, we may use your personal information to notify you of new product releases and services, to send service notifications to improve our services, to provide reporting, to conduct research, and to solicit your feedback and input about the AppOnboard Services.

Any use of any personal information you voluntarily submit to the website for marketing, feedback and other notification purposes will be explained at the point of collection and limited to the purposes specified at that time.

Information Sharing and Disclosure

AppOnboard may disclose information about Business Partners and visitors to the AppOnboard Website with certain third parties for lawful purposes.

Sharing with Service Providers

We may sometimes use other businesses (“Service Providers”) to perform certain services for us or on our behalf, such as analytics, messaging, payment processing, hosting and maintenance, and data storage and management services. We provide our Service Providers with the information reasonably necessary for them to perform the services on our behalf.  Each Service Provider must agree to implement and maintain reasonable security procedures and practices appropriate to the nature of the information involved in order to protect your information from unauthorized access, destruction, use, modification or disclosure.

Other Legal Purposes

AppOnboard may access, preserve, and disclose any information we have collected about you or that you have submitted to us as required for legal purposes, including:

  • In response to subpoenas, court orders, or legal process, or to establish, protect or exercise our legal rights or defend against legal claims;
  • To protect the rights and property of AppOnboard, Business Partners (including advertisers and publishers), our licensors, or the public;
  • If we believe it is necessary in order to investigate, prevent or take action regarding illegal activities, fraud, or violations of the personal or intellectual property rights of others or situations involving potential threats to the safety of any person;
  • To our corporate affiliates, joint ventures or other companies under common control with AppOnboard (in which case we will require such entities to honor this Privacy Policy); and
  • If AppOnboard is acquired by or merged with another entity or in connection with a sale of our assets.
Information Collected by Others

Please be advised that we do not control and are not responsible for the privacy practices of any third party, including, but not limited to, Business Partners and any website or service that links to or from our Website or the AppOnboard Services. We require Business Partners to maintain a privacy policy that fully and accurately discloses their data collection practices. Please be sure to review the privacy policies of any websites and applications that you may use.

This site may contain links to other sites. AppOnboard is not responsible for the privacy practices or content of these other sites. When you leave our Website or view a portion of a third party’s site through our Website, you are responsible for reading the privacy policies of each such site. This Privacy Policy applies solely to information collected by AppOnboard.

Visitors to Our Social Media Platforms

If you visit us on social media networks such as Facebook, Instagram, Twitter, LinkedIn, YouTube or Vimeo, then your personal data will be processed as described in this Policy and in the privacy policies of the respective social media platform. Be sure to review the privacy policy for each social media network through which you interact with AppOnboard to learn how and why each platform collects and processes your personal information.

AppOnboard and others visiting our social media pages may view and interact with information you enter on our social media pages, such as comments, videos, images, likes, public messages, etc. AppOnboard may delete content that you post to our pages should it be necessary, e.g., due to inappropriateness or regulatory guidelines. We may also use our social media accounts to communicate with you on these platforms.

Privacy Practices of our Business Partners

AppOnboard requires Business Partners to comply with all applicable laws and regulations regarding data privacy and security.  Independently, our Business Partners are also required to comply with such laws and regulations.  All users are responsible for reviewing the privacy policies of sites and Apps they visit for information about those sites’ and Apps’ data collection and use practices.

In some cases, including when required by applicable laws and regulations, our Business Partners may provide End Users with notice of the collection of data for advertising purposes as outlined in this Privacy Policy and may obtain all necessary consents on behalf of AppOnboard.

Please be advised that we do not control and are not responsible for the privacy practices of any third party, including, but not limited to, Business Partners and any website or service that links to or from our Site or the AppOnboard Services. We require Business Partners to maintain a privacy policy that fully and accurately discloses their data collection practices. Please be sure to review the privacy policies of any websites and applications that you may use.

Rights of European Union Residents

AppOnboard complies with the European Union General Data Protection Regulation (“GDPR”). The GDPR requires that AppOnboard take particular measures to protect the personal data of European residents. If there is any conflict between this policy and the GDPR, the GDPR principles shall govern with respect to residents of the European Union.

Under the GDPR, you have the right to withdraw consent that you have given us to process your personal data (Article 7); to request access to your personal data stored at AppOnboard (Article 15 GDPR) and the right to data portability (Article 20). You also have the right to request corrections (Article 16 GDPR), deletion (Article 17 GDPR) or restriction (Article 18 GDPR) of your personal data stored at AppOnboard.

If you are an end user of a Playable Advertisement [or an App Store Playable Demo], we kindly ask that you make these requests via the info button in one of our advertisements [or demos]. This will direct you to an online form to submit your information so that we can confirm your device’s identity and ensure that we access the correct data.  In order to meet these requests, we will ask you to provide a contact email address. This allows us to send you the information you requested, or to confirm completion of any requests to correct, delete or restrict data (Article 19 GDPR).

If you are not an end user, you may send your requests for access, correction, deletion or restriction to the privacy officer of AppOnboard at privacy@apponboard.com.

If you are a European resident dissatisfied with the handling of your personal data by AppOnboard, you have the right to object to processing of your personal data at any time (Article 21 GDPR). You also the right to lodge a complaint with a supervisory authority.  You may send your concerns or objections about the processing of your personal data to the privacy officer of AppOnboard at privacy@apponboard.com.

Children

We do not engage in activities that require parental notice or consent under the U.S. Children’s Online Privacy Protection Act (COPPA).  Our App Store Playable Demos are not intended to be used for Apps primarily directed at children under the age of 13. Similarly, our Playable Advertisements are not intended to be displayed in Apps primarily directed to children under the age of 13.  If you believe that we have inadvertently collected information from a child under 13 that is subject to parental notice and consent under COPPA, please contact us using the contact information below to request deletion of such information.

When the European Union’s General Data Protection Regulation requires consent for the collection of personal data, we will not collect such personal data from End Users under 16 years of age (or such younger age as may be specified by the laws of a particular country).

Security

We use standard security procedures and practices appropriate to the nature of the information in an effort to protect information from unauthorized access, destruction, use, modification or disclosure.  We also require our Service Providers to implement and maintain reasonable security procedures and practices appropriate to the nature of the information we share with them.

No data transmission over the Internet or any wireless network can be guaranteed to be 100% secure.  As a result, while we strive to protect your information, we cannot and do not guarantee or warrant the security of any information transmitted to or from the Services.

Privacy Shield

AppOnboard, Inc. complies with the EU-U.S. Privacy Shield Framework (and the Swiss-U.S. Privacy Shield Framework(s)) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union (and Switzerland) to the United States.  AppOnboard has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

If you have a Privacy Shield-related complaint, please contact us as explained in the “Contact Us” section below. As part of our participation in Privacy Shield, if you have a dispute with us about our adherence to the Principles, we will seek to resolve it through our internal complaint resolution process, through the independent dispute resolution body JAMS, or, under certain conditions, through the Privacy Shield arbitration process.

Privacy Shield participants are subject to the investigatory and enforcement powers of the US Federal Trade Commission and other authorized statutory bodies. Under certain circumstances, participants may be liable for the transfer of personal information from the EU to third parties outside the EU. Learn more about Privacy Shield here.

To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Changes to This Privacy Policy

We may amend this privacy policy from time to time. If we make a material change to this policy, we will notify you by posting notice of these changes on our Website home page and in this Policy.

Contact Us

If you have questions about this policy, or inquiries, requests or complaints regarding your information, please contact us at privacy@apponboard.com. For GDPR-related inquiries, please include “GDPR” in the subject of your message.