Our Company
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Privacy Policy

Last Revised: May 10th, 2017

TRUSTe

 

TRUSTe

 

 

 

StartApp Inc. (“we,” “us,” “our” or “StartApp”) is a mobile advertising and data company that provides its mobile application developers, advertisers and publishers (“Business Partners”) with an advertising platform for the purpose of delivering targeted and personalized advertising to individuals who download, use or otherwise interact with App Developer’s app or our Services, as defines below (“User(s)”) (herein after the “Business Partners” and “User(s)” shall be collectively defined as “you” or “yours”).  Our technology enables our Business Partners to show Users more relevant advertising that is based on Users’ interests and behaviors. In order to provide these Services, we collect and use certain information about Users’ activity and preferences, all as detailed in this Privacy Policy (“Policy”).

 

StartApp recognizes the importance of your privacy and we take this issue very seriously. To this end, we have designed the StartApp Policy in a format that is easy to read so that you can clearly understand our privacy practices. We are committed to treating any information we collect with care and respect.

 

ACCEPTANCE OF THE TERMS: BY USING APP DEVELOPER’S APP OR THE STARTAPP SERVICES, AS APPLICABLE, YOU HEREBY AGREE TO THE TERMS OF THIS PRIVACY POLICY AND TO THE COLLECTION AND USE OF CERTAIN INFORMATION, AS DESCRIBED IN THID POLICY. ANY USE OR CONTINUED USE OF THE APP DEVELOPER’S APP OR STARTAPP SERVICES CONSTITUTES YOUR AGREEMENT AND CONSENT TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THESE TERMS, PLEASE DO NOT ACCESS, DOWNLOAD OR USE THE APP OR SERVICES.

 

This Policy describes the collection and use of the information provided or collected on or through (i) our websites, which is currently located at www.startapp.com Site(s)”); (ii) the monetization platform for our Business Partners; (iii) StartApp’s app developer partners’ (“App Developer”) that implement the StartApp Software Developer Kit (“SDK”) within their mobile app for the purpose of displaying advertisement; and (iv) any other online services (together with the aforementioned, shall be collectively defined hereinafter as the “Services”).

 

StartApp is a member of TRUSTe’s Data Collection Program, signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe’s program requirements including transparency, accountability and choice regarding the collection and use of your personal information. TRUSTe’s mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us through one of the methods listed below. If you are not satisfied with our response you can contact TRUSTe at: https://feedback-form.truste.com/watchdog/request. The TRUSTe program only covers information collected through the deployment of the StartApp’s collection and use of information from Users and Business Partners of StartApp’s Services.

 

This Policy is an integrated part of the StartApp’s the SDK License Agreement http://www.startapp.com/policy/publisher-terms/ as well as the Advertising Agreement http://www.startapp.com/policy/advertiser-terms/ which is a legally binding agreement between you and the StartApp.

 

This Policy covers the following topics:

  1. Types of Information We Collect
  2. Information We Collect from Business Partners
  3. Information We Collect from Users
  4. Use of Your Information by StartApp
  5. How We Collect Information
  6. Data Collection by Third Party
  7. Sharing Your Information with Other Companies
  8. Your Choices and Controls
  9. Children’s Privacy
  10. Data Security, Integrity, and Retention
  11. Do Not Track Disclosure
  12. Changes to the Policy
  13. Contact Us

If you have any questions about this Policy or our privacy practices, please do not hesitate to Contact Us.

 

  1. TYPES OF INFORMATION WE COLLECT

The first type of information is non-identifiable information which may be made available or gathered via your use of the App Developer’s app or the Services (“Non-Personal Information”). We are not aware of the identity of the User or Business Partner from which the Non-Personal Information was collected.

The Non-Personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including: (i) certain software and hardware information (i.e., operating system, type of device, etc.); (ii) the session ID, the time and date you access the mobile app or Site, connect or disconnect to the Services, etc.; (iii) browsing data such as: browser type, visited URL, etc.; (iv) your IP addresses or Android ID or Advertising ID, MAC address or Device ID. Please note, we consider this data to be Non-Personal Information, however, in some countries and jurisdictions this data might be considered as identifying and “Personal Information”.

 

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). Personal Information includes your email address and private password submitted upon registration and contact information such as your name, telephone number, address upon a submitting voluntarily request to contact us.

 

Please note that we may collect different categories of Personal and Non-Personal information from you depending on the nature of your interaction with the Services, as detailed below. If we combine Personal Information with Non-Personal Information, the combined information will be treated as Personal Information for as long as it remains combined.

 

  1. INFORMATION WE COLLECT FROM BUSINESS PARTNERS

If you are one of our Business Partner, we may collect the following information from you:

  • Registration: information that you provide when you create a StartApp account. For example, in order to register to the Services, we require basic contact information such as: first and last name, email address and company name, company address, etc. Further, during the registration process the Business Partners will be requires to create a username and password, you hereby represent and warrant the you are responsible for maintaining the confidentiality of your username and password.
  • Payment: In order to submit payment to us for the use of the Services, or receive payments from us, as applicable, you will be required to fill in your payment details, such as: bank or financial account information, credit card or debit card numbers, PayPal account, etc.

You represent and warrant that you will not provide inaccurate, misleading or false information to StartApp. If information provided to StartApp subsequently becomes inaccurate, not updated, misleading or false, you will promptly notify StartApp of such change.

  • Technical: we also collect viewing and usage information that relates to your interaction with the Site, such as your physical location, your IP address, the amount of time you spend viewing certain portions of the Site, etc.
  • Newsletter Subscription: If you voluntarily subscribe to our Newsletter you will be asked to provide us with your email address, you can unsubscribe at any moment through your account or by clicking unsubscribe.

 

  1. INFORMATION WE COLLECT FROM USERS

The StartApp’s SDK, which is integrated into each App Developers mobile app, is software that allows our Business Partners to provide you with personalized content, including advertisement. By downloading and using the mobile app, Users grant the App Developer with permission to collect such Device Information and share it with StartApp. StartApp may track this information over time and across multiple apps (and may also combine the Device Information with Non-Personal Information from other sources) in order to deliver targeted advertisements through the Services. This information we collect and transfer includes non-sensitive device information, such as:

  • GPS location or other geolocation data;
  • Bluetooth devices and your device’s sensors such as the accelerometer, etc.;
  • Carrier, ISPs;
  • Device properties such as: operating system, operating system version, device type.;
  • Name of the App Developer’s mobile application through which a User interacts with the Services;
  • Language settings;
  • Network connection details and WiFi data;
  • Internet browser used to access the Services;
  • A fingerprint of your installed applications that does not identify them; and
  • IP Address and Advertising ID or Android ID (solely when the Advertising ID is not available). Please note, we consider this data to be Non-Personal Information, however, in some countries and jurisdictions this data might be considered as identifying and “Personal Information”.

 

  1. USE OF YOUR INFORMATION BY STARTAPP

StartApp uses the information it collects about you to provide the Services and to gain a better understanding of the products and services that may interest you and other Users. We may use your information in order to:

  • Operate, manage and improve the Services;
  • Respond to your inquiries;
  • Provide you with requested services;
  • Communicate with you about your StratApp account, your interactions with the Services or your contacts’ interactions with the Services;
  • Protect the rights or property of StratApp or third parties; and
  • Deliver targeted advertisements on behalf of our Business Partners. You may opt-out of receiving such targeted advertisements as set forth below.

 

  1. HOW WE COLLECT INFORMATION

Depending on the nature of your interaction with the Services, StartApp may collect information from you automatically or when you voluntarily choose to provide us with information, all as detailed hereinabove. We may also acquire information from other trusted sources to update or supplement the information that you voluntarily provide to us or that we collect automatically. Whenever technically possible, we will ask for your consent to collect your Personal Information and offer you the choice to opt-out.

If you are a visitor to the Site or a Business Partner, we collect information that you voluntarily provide us during your interaction with the Services solely for the purpose of providing the Services.

We may also collect certain types of information automatically, including through the use of Cookies, Web Beacons and other similar tracking technologies (as details below). These tracking technologies allow StartApp to personalize your experience with the Services (e.g., remember your password when you login).

StartApp primarily collects information from Users when an App developer serve an advertisement to a User by using the StartApp SDK, as detailed above. By downloading and using App Developer mobile app, you grant the App Developer with permission to collect device information and share it with StartApp.

For additional information regarding choices you may have with respect to our use of your information, please refer to the Your Choices and Controls section of the Policy.

 

  1. DATA COLLECTION BY THIRD PARTY

When you access or use the App Developers’ mobile apps or StartApp Services, we may use industry-wide technologies such as “cookies” (or similar technologies), which store certain information on your computer (i.e., locally stored) and which will allow us to customize the Service and content as well as enhance your experience of the Services. The cookies used by us are created per session and do not include any Personal Information, other than your preference, navigation on the applicable app as well as the session key and are removed as your session ends. Most browsers will allow you to erase cookies from your device, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies your experience may be limited.

Third parties (i.e., Google Analytics) may also use cookies, scripts or web beacons for the purpose of tracking and analyzing your use, this information does not include Personal Information. To learn more how Google uses data from our use of Google Analytics Cookie we recommend you review Google’s policies located at: www.google.com/policies/privacy/partners. We also encourage you to review the Google Analytics’ currently available opt-outs for the web tool available at:  https://tools.google.com/dlpage/gaoptout/

In addition, the Services and Site may link to third party non- StratApp websites and apps or other third party content (“Third Party content”). Please note that these features are provided by StartApp only as a suggestion. The Third Party Content is not reviewed or examined by us. StratApp cannot control the content or treatment of your information by such third parties, and that the privacy practices of third parties likely differ from those described in the Policy. We encourage you to carefully read the privacy policies and terms of use of those third parties.

StartApp is not responsible for the content of any Third Party Content, or any additional links contained therein nor for the quality or accuracy, timeliness, completeness, safety or adequacy, fitness for a particular purpose of any content of any such Third Party Content. The offering of these features does not imply StartApp’s endorsement of, or association with the Third Party Content. We make best efforts to ensure the Third Party Content will not harm your experience, however we cannot represent or warrant to such Third Party Content. It is your sole responsibility to comply with the appropriate terms and conditions of the Third Parties Content as well as with any other obligation under copyright, secrecy, defamation, decency, privacy, security and export laws related to the use of such Third Party Content and any content contained thereon. In no event shall the StartApp be liable to anyone for any damage arising from or occasioned by the creation or use of the Third Party Content or the information or material accessed-through these Third Party Content. StartApp may at its sole discretion add, change, decline or remove, without notice, any feature or link to any of the Third Party Content from the Service or site.

 

  1. SHARING YOUR INFORMATION WITH OTHER COMPANIES

StratApp will not share any Personal Information collected from you with third parties or any of our partners except in the following events: (i) Authorized Disclosures. we may disclose your personal information to third parties when you consent to a particular disclosure of your personal information. Please note that once we share your information with another company, that information becomes subject to the other company’s privacy practices. (ii) Compelled Disclosures. we will share your information, solely to the extent needed to comply with any applicable law or permitted by it, regulation, legal process or governmental request (e.g., pursuant to law enforcement inquiries, subpoenas or court orders), or when we believe, in good faith, it is required in order to enforce our policies (including our policies and agreements) including investigations of potential violations thereof or to detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues. In addition, we will share your information, solely to the extent needed to establish or exercise our rights to defend against legal claims or to prevent harm to the rights, property or safety of us, our users, yourself or any third party or for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights. (iii) Agents / Service Providers. we may disclose personal information to our trusted agents and service providers so that they can perform requested services on our behalf. For example, we may share payment information with a third-party service provider in order to assist us with processing credit card payments. These entities are prohibited from using your personal information for any purposes other than providing StratApp with requested services. (iv) Business Transfers. we may share Personal Information, in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy. (v) Non-Personal Information. We may share aggregate or anonymous information with Business Partners and other third parties in accordance with the terms of this Policy. We may store Non-Personal and Personal Information on our servers or our cloud servers, use or share Non-Personal Information in any of the above circumstances, as well as for the purpose of providing and improving our App and Service, aggregate statistics, marketing and conduct business and marketing analysis, and enhance your experience with the App.

 

Furthermore, we reserve the right to use, disclose or transfer (for business purpose or otherwise) aggregated and processed data to third parties, including, inter alia, business partners, affiliates and consultants, for various purposes including commercial use. This information may be collected, processed and analyzed by the StartApp and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other users) to third parties.

 

  1. YOUR CHOICES AND CONTROLS

StratApp provides you with the ability to exercise certain choices and controls in connection with our treatment of your information. Depending on your relationship with StratApp, these choices and controls may include:

  • Requesting access to the Personal Information collected about you that we hold;
  • Correcting, updating or deleting the information associated with your StratApp account;
  • Opting-out of targeted advertising delivered by StratApp, please note this does not mean you will not receive advertisement this solely provides you with the choice to receive advertisement that is not targeted to you and to control the data collected on you for the purpose of displaying advertisement.

In the event you make such request, note that we may require certain information from you in order to verify your identity and locate your data and that the process of locating and deleting the data may take reasonable time and effort. Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.

If you would like additional information about the choices and controls that may be available to you, or you would like to access your personal information, please Contact Us. We will respond within a reasonable time.

 

Even after providing your consent to this Policy, you are entitled to change your mind. If you do, you may easily opt out of the data collection, sharing process and targeted advertising services related to our StratApp App and Service. Please note that even if you opt-out, you may still receive content and advertising from StratApp. Opting-out just means that the advertisements you do receive from us will not be targeted in any sort of way.

Please read your device specific information to learn how to opt-out: Android- https://support.google.com/ads/answer/2662922 OR iOS – https://support.apple.com/en-il/HT205223.

 

You may also Contact Us and we will be happy to assist you. Note that once you opt out, part of the Service provided by us might no longer be available and some features may not work if you revoke the data transfer.

  • You may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser.
  • You may limit the disclosure of certain Non-Personal Information by your mobile device to us and our Business Partners by adjusting the settings on your mobile device. For iOS mobile Devices, go to “Settings” from your Device’s home screen; scroll down to “Privacy”; select “Advertising”; and turn on “Limit Ad Tracking.” For Android mobile Devices, go to “Google Settings” on your Device; select “Ads”; and check the box labeled “Opt Out of Interest-Based Ads.”
  • You may opt out of certain advertisers’ cookies and browser-enabled, interest-based advertising at the Network Advertising Initiative’s (“NAI”) website- NAI consumer opt-out and the Digital Advertising Alliance’s (“DAA”) website- DAA opt-out page.
  • Our Business Partners may also provide ways for you to opt out from or limit their collection of information from and about you. Please refer to the privacy policies for the Apps to learn more about the privacy practices of our Business Partners. Please note, however, that we are not responsible for the privacy practices of Our Business Partners, and other third parties.

 

  1. CHILDREN’S PRIVACY

You represent and warrant that you are at least 13 years of age and of legal competence to enter into these Terms. If you are under 18, please be sure to read the Terms with your parents or legal guardians. If a partner flags their application or mobile website as directed towards children under 13, we will not collect any information on these users for behavioral marketing, profile building, or remarketing purposes.

We do not use the Services to knowingly solicit data from or market to children under the age of thirteen (13). We request that such individuals do not provide Personal Information through the Services.

If you become aware or have any reason to believe that a child under the age of 13 has shared any information with us, please contact us and we take reasonable steps to ensure that such information is deleted from our files.

 

  • DATA SECURITY, INTEGRITY AND RETENTION

Your privacy is very important to StratApp and we are committed to protecting your Personal Information from unauthorized access, use or disclosure. We have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry standards. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Services, and we make no warranty, express, implied or otherwise, that we will be able to prevent such access. We may adopt what we believe is appropriate data collection, storage and processing practices and security measures to protect against unauthorized access to such data.

StartApp also protects User privacy by seeking to minimize the amount of data that we store on our servers in the first place. If you feel that your privacy was treated not in accordance with our policy, or if any person attempted to abuse StartApp please contact us directly.

We retain the information we collect for as long as needed to provide the Service and to comply with our legal obligations, resolve disputes and enforce our agreements.

StartApp may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

 

  • TRANSFER OF DATA

StratApp may process or store Personal Information both within the United States and internationally, therefore you hereby accept and agree that by accessing and using the Services from outside the United States, your information may be transferred to, stored, and processed in the United States.

 

  • DO NOT TRACK DISCLOSURE

The Service does not respond to Do Not Track signals. For more information about Do Not Track signals, please see http://www.allaboutdnt.com/

 

  • CHANGES TO THE POLICY

We reserve the right to periodically amend or revise this Policy From time to time, at our sole discretion. The most recent version of the Policy will always be posted on the Site. If we do make any changes, the updated date at the top of the Policy will be reflected in the “Last Revised” heading. If we make any material changes, that will substantially affect your use of the Service or the data collection by us, we will make best efforts to provide you with notifications by email (sent to the e-mail address specified in your account) or by means of a notice on this Site. We encourage you to review the Policy periodically to ensure that you understand how we collect, use and share information through the Services.

Any changes to the Policy will become effective immediately upon the display of the revised Policy. Your continued use of the App or Services following the display of such revised Policy, constitutes your acknowledgement and consent of such amendments and your agreement to be bound by the terms therein

 

  • CONTACT US

If you have any questions or comments about this Policy, please write to us at:

StartApp Inc.
584 Broadway St. 12th Floor Suite 1206 New York, NY, 10012

You can also contact us via email at: Support@startapp.com.

Please be sure to include your name, address and email address in any correspondence to us so that we can respond to your inquiry in a timely manner.