Privacy Policy (original) (raw)

Effective Date: September 12, 2022

This Privacy Policy covers the Personal Information practices of any website (including, https://youappi.com/) that links to this Privacy Policy (severally and jointly, the “Site”) and is operated by YouAppi Inc. or its affiliates and subsidiaries companies (“YouAppi”, “we”, “us” or “ours”), and the advertising services (the “Services”) that YouAppi provides to its supply and demand partners.

In this Privacy Policy, Personal Information is any combination of information, in the possession of or likely to come into the possession of YouAppi, that can be used to identify, contact, or locate a discrete individual (“Personal Information”). Personal Information includes any expression of opinion about an individual. Generally speaking, information that does not identify a discrete individual (such as aggregated statistical information) is not considered Personal Information. Please read this Privacy Policy carefully, before using the Site or the Services, so you can fully understand our practices in relation to Personal Information, before we begin processing your information. Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.

This Privacy Policy explains:

1. WHAT PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT
2. DISCLOSURE OF PERSONAL INFORMATION TO OTHERS
3. TRANSFERS TO THIRD COUNTRIES
4. YOUR RIGHTS
5. YOUR ADVERTISEMENT OPT OUT CHOICES
6. HOW WE PROTECT YOUR PERSONAL INFORMATION
7. DO NOT TRACK
8. EXTERNAL LINKS
9. USE BY CHILDREN
10. HOW TO CONTACT US
11. CHANGES TO THIS PRIVACY POLICY

The information gathered by YouAppi from the Site is either Personal Information voluntarily supplied by Site users or tracking information gathered as users navigate through the Site. In these instances, YouAppi is considered a data controller of this Personal Information. Please note that you are not required by law to provide us with any such Personal Information.

YouAppi is a company that provides mobile app developers with user acquisition and retargeting services to grow their businesses. In addition, when you use the Services as a demand partner or supply partner, YouAppi collects Personal Information about your end users in order to provide you with the Services. When collecting this Personal Information, YouAppi acts as a processor of this Personal Information. If you are an individual, using YouAppi's Services as a result of our relationship with YouAppi’s customer ("Individual(s)"), please note that the customer is the responsible party for obtaining the required consents and complying with any applicable laws or regulations.

1. WHAT PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT.

(I) Personal Information voluntarily provided by you on the Site.

When using the Site, you can provide us with Personal Information to help us serve your needs. The Personal Information that we collect will depend on how you use the Site. For the purposes listed below, YouAppi acts as a data controller.

1. a) When you submit Personal Information and/or a request via our Site

• Personal Information collected and for which purposes. Legal basis: When you request Personal Information about our Services (including, contact us form, request a demo, you must submit your full name, phone number, company details (to the extent that it contains Personal Information) and e-mail address. In addition, if you insert the reason for your communication that could contain additional Personal Information (provided voluntarily by you). The legal basis are: processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract and our legitimate interest in answering your questions and inquires. We will use this Personal Information to:
  • Determine whether you are an existing client of YouAppi;
  • Send you the material you have requested;
  • Assist you in the completion of your application;
  • Assess your eligibility for any requested service
  • Responding to your inquiries about accounts and other Services; and
  • Making proposals for future service needs.
  • Also, we will send you marketing communications (in accordance with your consent)
• Third parties with whom we share your Personal Information: Wordpress, Salesforce, Hubspot, AWS and Outreach.io.
• Retention period: We will retain your Personal Information for the amount of time necessary in order to process your inquiries and respond to your requests. If we have not received a communication from you within 9 months, or you have asked to delete your Personal Information, we will delete records of your Personal Information, please note that in some circumstances we may store your Personal Data for longer periods of time.
• Consequences of not providing the Personal Information: We cannot (i) Determine whether you are an existing client of YouAppi; (ii) send you the material you have requested; (iii) assist you in the completion of your application; (iv) assess your eligibility for any requested service; (v) responding to your inquiries about accounts and other Services; (vi) making proposals for future service needs; and (vii) send you marketing communications (in accordance with your consent).

1. b) When you register to our Services

• Personal Information collected and for which purposes. Legal basis: Following an inquiry into receiving the Services from us and when you register to proceed with the Services, we ask you for your name, your position and the organization you work for, e-mail address, country, postcode, telephone number, billing address or payment details.
• The legal basis for processing this Personal Information are: the performance of a contract with you and our legitimate interest in providing you the Services requested by you. We use this Personal Information to:
• • • Provide and maintain the Service to you, including performing payment processing operations (through third party service providers);
      • Renew the Service;
      • Establish and maintain communications with you and other users;
      • Make proposals for future service and product needs;
      • To create users for your use of our platform/dashboard
      • To perform/execute the agreement
      • To grant you and your admin users access to the services (our platform/dashboard)
      • To manage your everyday business needs (e.g., administration of your users / log-in to the Services)
  • **Third parties with whom we share your Personal Information:**AWS for cloud purposes; Hubspot and SalesForce for CRM purposes.
  • Retention period: To the extent that you are using the Services, we will store your Personal Information for the period in which you have an account with us to provide you with the Services. After you close your account, we will retain your Personal Information only to the extent required or allowed by applicable law.
  • Consequences of not providing the Personal Information: We cannot (i) provide and maintain the Service to you; (ii) renew the Services; (iii) establish and maintain communications with you and other users; (iv) make proposals for future service and product needs; and/or (v) allow our affiliated companies to notify you of certain products or Services they offer.

1. c) When you are a candidate and you submit your CV

• Personal Information collected and for which purposes. Legal basis: Full name, email address, phone number, resume/CV, LinkedIn profile and any other information that you decide to provide/supply us. The legal basis for processing this Personal Information are: Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. Legitimate interest (e.g. to assess a candidate). We use this Personal Information to**_:_**
  • Process your job application, and
  • Assess the candidate.
  • Note: For the avoidance of doubt, this use case shall apply to the CVs submitted by the Website or by any other methods (e.g., HR and recruitment agencies).
• Third parties with whom we share your Personal Information: LinkedIn and Fresh Team.
• Retention period: Your Personal Information will be stored until we delete the record and we proactively delete it or you send a valid deletion request please note that in some circumstances we may store your Personal Information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings.
• Consequences of not providing the Personal Information: We cannot (i) process your job application and (ii) assess you as a candidate.

(II) Tracking Information when users navigate the Site.

As you navigate this Site, we also use commonly-used information-gathering tools, such as cookies and web beacons to operate the Site and provide you with certain features and functionalities. These tools collect standard information from your web browser (such as browser type and browser language), your Internet Protocol (“IP”) address and the actions you take on the Site (such as the web pages viewed and the links clicked). The legal basis for processing this information is for the performance of a contract with you and our legitimate interest in being able to provide and improve the functionalities of the Site offered to you. If you are located in the European Union, we also rely on your consent to use cookies. Like many companies, we uses cookies on the Site. Cookies are pieces of information shared between your web browser and the Site. Cookies enable us to offer a faster and easier user experience. For more information about the cookies that we use, please visit our cookie notice https://youappi.com/cookie-policy/

Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with Personal Information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

(III) Personal Information when our customer make use of the Services.

1. a) When we provide our services to our customers.

• Personal Information collected and for which purposes: When you make use of the Services as a demand partner or supply partner, YouAppi collects Personal Information about your end users in order to provide you with the Services. YouAppi collects or receives information about the end user’s device and the ads it view or click. The Services are designed to avoid collecting information that identifies you personally, such as your name, address, or email address, but the information we collect may enable us to recognize your device over time. YouAppi’s Services collects (depending on the case) the following categories of end user Personal Information:
• Mobile Advertising ID for Services performed via a mobile device; and
• IP address. We also collect other non-Personal Information in providing the Services including:
• Device make, model and operating system;
• Device properties related to screen size & orientation, audio volume and battery;
• Carrier;
• Operating system;
• Name and properties of mobile application through which a consumer interacts with the Services;
• Country, time zone and locale settings (country and preferred language);
• Network connection type and speed;
• Activity of a user on an application following installation; and
• Internet browser user-agent used to access the Services.
• Services to Supply Partners: YouAppi uses these Personal Information to find and serve the optimal advertisement for the end user of your mobile website or application (the “Property”). In addition, YouAppi passes these Personal Information on to the Advertiser’s tracking vendor for tracking purposes so that an install event can be detected (which then triggers a payment to you, i.e., the Supply Partner). Please note that YouAppi only collects Personal Information from the Property to the extent that you, our customer, have instructed YouAppi (in accordance with the permissions you have activated inside the Property) to collect, use and share the Personal Information with advertisers, demand partners and other relevant third parties, in order to provide the Services and.
• Services to Demand Partners: YouAppi uses these Personal Information to facilitate and optimize campaigns for advertisers across its network. It only uses the Personal Information provided by a demand partner to optimize campaigns for this demand partner – YouAppi does not cross-use Personal Information received from one advertiser to optimize the campaigns of another advertiser. YouAppi will receive Personal Information from your tracking vendor on whether an event which triggers payment to YouAppi or measures quality of the installs provided by YouAppi has occurred on a Property. This is so we can serve your advertisement on the Properties of our supply partners and pay them for certain events agreed between us (e.g., installs, certain interactions on a Property etc). YouAppi shares the Personal Information with advertisers, measurement/attribution partners, and with our technical infrastructure vendor (AWS), for the purpose of providing our Services.
• Additional processing activities: We also use these Personal Information to detect and prevent fraudulent actions of end users. For example, we will detect multiple requests from a certain piece of information (e.g., IP address) that could not reasonably be performed by a human being in such time or volume.
• Third parties with whom we share your Personal Information: (i) With advertisers and demand partners (including advertisers, and measurement/attribution partners) for the purposes of providing our Services; (ii) aggregated and non-Personal Information: We share aggregate or non-personally identifiable information about the use of our Services with the relevant customer. For example, we provide advertisers reports showing how many users viewed or clicked on their ads. We also provide publishers reports about the types of ads served to their mobile apps; and (iv) with our vendors and service providers to provide the Services, such as providing technical infrastructure services.
• Retention period: We will retain the Personal Information described above for the life of an active campaign and for six (6) months thereafter, or until you (our customer) instruct us otherwise to delete such Personal Information, noting that we will continue to retain your Personal Information for longer periods only to the extent required or allowed by applicable law or auditing requirements.
• The iOS mobile devices may provide an 'App Tracking Transparency' setting. On Android devices, your settings may allow you to 'Opt out of Interest-Based Ads.' When you, as an Individual, have opted out using this setting on a device, YouAppi will not use in-app information collected from that device to infer your interests or serve ads to that device that are targeted based on your inferred interests.
• Note: For the avoidance of doubt, we will process the Personal Data stated in this use case on behalf of our customers when providing the services to them. If you have any questions regarding this processing, please note that the Customer is the responsible party for obtaining the required consents and complying with any applicable laws or regulations. Therefore, you should closely review the privacy policies of the applications and websites that you make use in order to learn about the privacy practices of our Customers.

(IV) When we use the Personal Information of our customers (e.g. contact details)

• Personal Information collected and for which purposes. Legal basis: When our customer supply us with information containing third-party Personal Information (names, addresses, or other Personal Information relating to living individuals) excluding Personal Information of end users provided in connection with your use of the Services, we will hold and use such Personal Information to perform Services and communicate with you (our customer) on the understanding that the individuals to whom the Personal Information relates have been informed of the reason for which you shared such Personal Information with us.
• Third parties with whom we share your Personal Information: Amazon Web Services, Google, Salesforce, Hubspot.
• Retention period: We will retain the Personal Information described above for the period in which we have an active business relationship with you or until you ask us to delete such data, note that we may receive consent directly from the data subject of such Personal Information, in which case the retention period and use shall be governed by our relationship with such data subject.
• Consequences of not providing the Personal Information: We cannot provide you with the services and to send you service-related communications.

(v) When you attend a marketing event and/or we exchange business cards and you provide us with your Personal Information

• Personal Information collected and for which purposes. Legal basis: First name, last name, email address, company name, contact information, and any other data you decide to supply. The legal basis for processing this Personal Information are: depending on the context consent and/or legitimate interest (e.g. to send you B2B communications). We use this Personal Information to:
  • Establish a business connection;
  • Allow you to participate in webinar and other events that we organize (including, to send you event-related communications); and
  • Send you marketing communications
• Third parties with whom we share your Personal Information: Salesforce, Hubspot, event organizer
• Retention period: Your Personal Information will be stored until we delete the record and we proactively delete it or you send a valid deletion request please note that in some circumstances we may store your Personal Information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings.
• Consequences of not providing the Personal Information: We cannot: (i) establish a business connection, (ii) Allow you to participate in webinar and other events that we organize, and (iii) send you marketing communications.

(vi) When we acquire your Personal Information from third-party sources (such as lead-generation companies)

• Personal Information collected and for which purposes. Legal basis: Contact details. The legal basis for processing this Personal Information are: Depending on the context, legitimate interest (B2B marketing), pre-contractual discussions or consent. We use this Personal Information to:
  • Establish a business connection; and
  • Send you marketing communications
• Third parties with whom we share your Personal Information: Google docs
• Retention period: Your Personal Information will be stored until we delete the record and we proactively delete it or you send a valid deletion request please note that in some circumstances we may store your Personal Information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings.
• Consequences of not providing the Personal Information: We cannot: (i) establish a business connection and(ii) send you marketing communications.

(vii) When we use the Personal Information of our service providers (e.g. contact details)

• Personal Information collected and for which purposes. Legal basis: Full name, email address, job title, company name, phone number, contact information and any other data you decide to supply us with. The legal basis for processing this Personal Information are: Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract and Legitimate interest (e.g. communicate with our service providers and suppliers). We use this Personal Information to:
• Perform of the applicable contract; and
• Send you contract-related communications.
• Third parties with whom we share your Personal Information: Google Drive and Priority
• Retention period: Your Personal Information will be stored until we delete the record and we proactively delete it or you send a valid deletion request please note that in some circumstances we may store your Personal Information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings.
• Consequences of not providing the Personal Information: We cannot: (i) perform the applicable contract and (ii) send you contract related communications.

(viii) When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)

• Personal Information collected and for which purposes. Legal basis: Full name, email address, company name, job position, social media profile, and any other data you decide to provide/supply us with. The legal basis for processing this Personal Information are: Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, legitimate interest (e.g., to answer your questions) and/or consent. We use this Personal Information to:
• reply and/or respond to your request or question;
• establish a first business connection/discussion; and
• send you more information about YouAppi.
• Third parties with whom we share your Personal Information: Google docs and social media channels that we use
• Retention period: Your Personal Information will be stored until we delete the record and we proactively delete it or you send a valid deletion request please note that in some circumstances we may store your Personal Information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings.
• Consequences of not providing the Personal Information: We cannot: (i) reply and/or respond to your request or question, (ii) establish a first business connection/discussion, and (iii) send you more information about YouAppi.

Finally, please note that some of the abovementioned Personal Information will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Information may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Information and further use it for internal and external purposes, including, without limitation, to improve the Services and for research purposes. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our Services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our Services and enhance your experience with them).

2. DISCLOSURE OF PERSONAL INFORMATION TO OTHERS.

We disclose Personal Information about you with third parties as stated in this Privacy Policy, as permitted by law, or authorized by you. Third parties to whom we disclose Personal Information include the ones described above and the following ones:

• Service providers who assist in providing the Site and the Service including:
  • Payment processing service providers are used to process transactions for the Services. They will receive your banking and payment details;
  • Tracking vendors which assist in providing the Services to Demand and Supply Partners; and
  • Communication and marketing platforms are used to communicate with you and notify you of our products and services;
  • Providers of core business infrastructure such as hosting platforms and back-up providers. They are used to store all Personal Information collected by YouAppi.
• In the normal course of providing Services for our clients, we share Personal Information within YouAppi and its affiliates for system administration, storing or processing such Personal Information on our behalf to provide the Site and the Services, and for crime, fraud prevention or detection and compliance with applicable law.
• As we continue to develop our business, if, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Information to such third party (whether actual or potential) in connection with the foregoing events. Also, in the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Information in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company.
• YouAppi preserves the right to disclose without your prior permission any Personal Information about you or your use of the Site or the Services if YouAppi has a good faith belief that such action is necessary to: (a) protect and defend the rights, property or safety of YouAppi, employees, other users of the Site, the Services or the public; (b) enforce the terms and conditions that apply to use of the Site and the Services; (c) as required by a legally valid request from a competent governmental authority, or as required by law, including for tax or accounting purposes, in response to their requests for such information or to assist in investigations; or (d) to third parties in connection with claims, disputes or litigation, when otherwise required by law or court order, or as otherwise required to respond to claims that any content violates the rights of third-parties. We may also disclose Personal Information as we deem necessary to satisfy any applicable law, regulation, legal process or governmental requests.
• Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).

3. TRANSFERS TO THIRD COUNTRIES.

Storage: YouAppi is located and maintains servers and other storage facilities with AWS with servers located in the United States, Ireland and Japan (for support of the Services provided in Japan).

Transfers: YouAppi will take appropriate steps to ensure that transfers of Personal Information are in accordance with applicable laws and carefully managed to protect your privacy rights and interests. To this end:

• External transfers: where we transfer your Personal Information outside of EU/EEA, for example to the service providers listed above, we obtain contractual commitments from them to protect your Personal Information. Some of these assurances are adequacy decision of the European Commission confirming an adequate level of data protection in the respective non-EEA country or an agreement on the basis of the EU Model Clauses (a set of clauses issued by the European Commission); or
• Internal transfers: We ensure transfers within the YouAppi group will be covered by an agreement entered into by members of the YouAppi group (an intra-group agreement) which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to.

Subject to applicable laws, you have a right to contact us for more Personal Information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your Personal Information when this is transferred as mentioned above. See “Your Rights” section below for more details.

4. YOUR RIGHTS.

4.1. YouAppi does not provide online access to its customers to view or amend Personal Information in its database, however, you have the right to ask YouAppi to amend any Personal Information it holds about you if it is inaccurate. We also note that our knowing about changes to some of your Personal Information (e.g. email address) may be key to effectively communicating with you at your request so we encourage you keep us informed of changes to your Personal Information. To update your details, please contact us by email at privacyprotection@youappi.com or at the following address: YouAppi Inc. Attn: Customer Care 228 Hamilton Ave 3rd Floor, Palo Alto, CA 94301.

4.2. The following rights (which may be subject to certain exemptions or derogations), shall apply to individuals protected by the GDPR:

• You have a right to access Personal Information held about you. Your right of access can normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law.
• If you no longer want us to use your Personal Information, you can request that we erase your Personal Information. Please note that if you request the erasure of your Personal Information, we will not be able to process your transactions or provide you with the Services. We may retain some of your Personal Information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend use for fraud or safety reasons, we may retain certain Personal Information about that user from processing another transaction through the Site and the Service. We may also retain and use your Personal Information to the extent necessary to comply with our legal obligations, including for tax, legal reporting and auditing obligations. Also, because we maintain the Site and the Service to protect from accidental or malicious loss and destruction, residual copies of your Personal Information may not be removed from our backup systems for a limited period of time.
• You have a right to restrict the processing of your Personal Information, for example in case when we no longer need your Personal Information for the initial purposes for which they were collected, but they are required by you for the establishment, exercise or defense of legal claims.
• Where you have provided your consent to the processing of your Personal Information by YouAppi you may withdraw your consent (opting out) at any time by sending a communication to us specifying which consent you are withdrawing. Please note that the withdrawal of your consent (opting out) does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
• You have a right to object to our use of your Personal Information for direct marketing purposes. See the “Direct Marketing” section and the explanation of “Cookies” above for how to unsubscribe, manage your marketing preferences and opt out of cookies.
• You have a right to obtain a portable copy of Personal Information which is processed on the basis of your consent, or which is necessary for the performance of a contract between us. You have a right to have such portable copy of Personal Information transferred to another data controller in a structured, commonly used and machine-readable format.
• You also have a right to request details of the basis on which your Personal Information is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.
• You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your Personal Information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

4.3. The following rights (which may be subject to certain exemptions or derogations) shall apply to individuals protected by the CCPA:

• You have the right to know what Personal Information is being collected about you, This include the right to request that we disclose what Personal Information of yours we collect, use, disclose, and sell;
• You have the right to request the erasure/deletion of your Personal Information (e.g. from our records and the records of our service providers). Please note that there may be circumstances in which we are required to retain your Personal Information, for example for the establishment, exercise or defense of legal claims;
• You have the right to know whether your Personal Information is sold or disclosed and to whom;
• You have the right to restriction of, or object to, processing of your Personal Information, including the right to opt in or opt out of sale of your Personal Information to third parties, if applicable, where such requests are permitted by law;
• You have the right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA;
• You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence (e.g. the Attorney General in your State). We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

4.4. Where YouAppi relies on consent for the fair and lawful processing of Personal Information, the opportunity to consent will be provided when the Personal Information in question is collected. Where you have consented to the processing of your Personal Information, you may withdraw this consent (opting out) at any time and prevent further processing by contacting us as described in this Privacy Policy. YouAppi will inform you of the consequences of withdrawing your consent. In some cases, refusing to provide certain Personal Information or withdrawing consent (e.g., opting out) for YouAppi to collect, use or disclose your Personal Information could mean that we cannot provide the requested Services to you. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our services and for other legal purposes as described above. While we cannot guarantee privacy perfection, we will address any requests to the best of our ability as soon as possible. We will process such requests in accordance with applicable laws.

4.5. If you wish to withdraw your consent (which may limit or terminate the products and Services that YouAppi provides to you), simply tell us that you would like to withdraw your consent (opting out) through writing us at to privacyprotection@youappi.com. We will kindly ask you to be specific as to which specific type of processing of your Personal Information you would like to withdraw your consent.

4.6. We may ask you for additional Personal Information to confirm your identity and for security purposes, before disclosing the Personal Information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. You can exercise your rights by contacting us at privacyprotection@youappi.com. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further Personal Information in order to fulfil your request. In the event that your request, for example, would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with your request in a different way than initially requested, we will address your request to the maximum extent possible, all in accordance with applicable law. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

4.7. If you are an Individual, as a first step, please contact the relevant demand partner or supply partner (e.g., the mobile app that you are using). If you send a request related to your Personal Information directly to YouAppi, YouAppi will response to your deletion request as soon as possible and in accordance with applicable law.

5. YOUR ADVERTISEMENT OPT OUT CHOICES:

If you are receiving advertisements, please remember that we are the data processor and our customer is the data controller of your Personal Information. However, you can opt out of having your Personal Information being used by YouAppi for performance-based advertising by accessing your mobile device settings and following the instructions here. Please note that if you limit ad tracking or choose to opt out, you will still see advertisements, but YouAppi will no longer be able to use any Personal Information to serve you with more relevant ads.

In addition, the advertising identifier (along with any Personal Information collected about that identifier) that was previously assigned to you will also be disassociated. This means that if at a later stage, you decide to opt back in, we will not be able to use any of your past Personal Information and you will, for all practical purposes, be a new user to our system.

6. HOW WE PROTECT YOUR PERSONAL INFORMATION.

We have implemented and will maintain appropriate technical and organizational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such Personal Information appropriate to the nature of the Personal Information concerned. Note that, although we take measures to secure the Personal Information we collect and reduce the risk of unwanted disclosure, we cannot guarantee that the Personal Information will not be exposed as a result of unauthorized penetration to our servers. Nevertheless, we make commercially reasonable efforts to make the collection and security of such Personal Information consistent with this Privacy Policy and all applicable laws and regulations. As the security of Personal Information depends in part on the security of the computer or device you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

7. DO NOT TRACK.

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We may collect personally identifiable information about an individual consumer’s online activities in our Site over time. If you choose to operate your web browser “do not track” signals or any other mechanism that provides consumers the ability to exercise choice regarding the collection of such information, we will abide by your request and stop collecting such information. We may allow third parties such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time when a consumer uses the Site.

8. EXTERNAL LINKS.

The Site or the Service may include links to other websites whose privacy policies we do not control. Once you leave our servers (you can tell where you are by checking the URL in the location bar on your web browser), use of any Personal Information you provide is governed by the privacy policy of the operator of the website you are visiting. That policy may differ from ours. If you can’t find the privacy policy of any of these websites via a link from the website’s homepage, you should contact the website directly for more Personal Information. Accordingly, we encourage you to read the terms and conditions and privacy policies of each third party Services.

9. USE BY CHILDREN

We do not offer our products or Services for use by children and, therefore, we do not knowingly collect Personal Information from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any Personal Information to us without involvement of a parent or a guardian. For the purposes of the GDPR, we do not intend to offer information society Services directly to children. In the event that we become aware that you provide Personal Information in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at privacyprotection@YouAppi.com.

10. HOW TO CONTACT US.

If you have any questions, concerns or complaints regarding our compliance with this Privacy Policy, or if you wish to exercise your rights, we encourage you to first contact us at privacyprotection@YouAppi.com. You can also contact us at the following address: YouAppi Inc. Attn: Customer Care 228 Hamilton Ave 3rd Floor, Palo Alto, CA 94301.

11. CHANGES TO THIS PRIVACY POLICY.

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement significant changes to the use of your Personal Information in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Site or by other means.