[Last Revised: September 25, 2018]
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 advertisements to individuals (“User(s)”) that download, use or otherwise interact with an App Developer’s app or our Services, as defined below.
- Our website available at startapp.com(“Site”), and any service or feature provided therein;
- The monetization platform for our Business Partners available at: https://portal.startapp.com/#/signin;
- StartApp’s app developer partners’ (“App Developer”) that implement the StartApp Software Developer Kit (“SDK”) within their mobile app (“app(s)”) for the purpose of displaying advertisements. As our technology enables our Business Partners to show Users more relevant advertising that is based on Users’ interests and behaviors, we collect and use certain data about Users’ activity and preferences, all as detailed in this Policy.
StartApp recognizes the importance of your privacy and we are committed to treating any data we collect with care and respect. To this end, we have designed this Policy in a format that is easy to read so that you can clearly understand which data is collected, how we process, use and protect your data, as well as your choice and controls, but before, we would like to explain the basis on which we do so:
- Where a Business Partner uses our Services, we process the Business Partner’s Personal Data in order to perform our contract with the Business Partner;
- When visitors access our Site or a user interacts with App Developer’s app, we collect certain online identifiers. Such online identifiers are processed under the lawful basis of our legitimate interests.
- For Business Partner direct marketing, we have legitimate interest to process such data; or
- We will also process your Personal Data where you have provided with consent to do so.
This Policy is an integrated part of StartApp’s Publisher Agreement available at: http://www.startapp.com/policy/publisher-terms/ as well as StartApp’s Advertiser Agreement available at: http://www.startapp.com/policy/advertiser-terms/.
If you have any questions about this Policy or our privacy practices, please do not hesitate to Contact Us.
Types of Data We Collect
Depending on your interaction with our Services (meaning, if you are just browsing our Site, or if you have registered to our Services, or interact with an app, etc.), we may collect two types of data, as follows:
- The first type of data is non-identifiable data which may be made available or gathered via your use of the app or the Services (“Non-Personal Data”). We are not aware of the identity of our Site visitors, User or Business Partner from which the Non-Personal Data was collected. The Non-Personal Data which is being collected may include aggregated usage information and technical information transmitted by a device, including but not limited to: (i) certain software and hardware information (e.g., type of device); (ii) the session ID, the time and date you access the app or our Site, connect or disconnect to the Services, etc.; and (iii) browsing data such as: browser type, visited URL, etc. (all as detailed below).
- The second type is individually identifiable data, namely data that identifies an individual or may with reasonable effort identify an individual (“Personal Data”). Personal Data includes either: (a) information you voluntarily provide us, such as 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; or (b) certain identifiers such Internet Protocol (“IP”) addresses or Android ID, Advertising ID, IDFA or Device ID (“IDs”). Note that, while IDs are considered as personally identifiable data in many jurisdictions (such as the EEA), there are some jurisdictions in which such data is not considered as Personal Data. We treat all IDs from various jurisdictions as Personal Data.
Please note that we may collect different categories of Personal and Non-Personal Data from you depending on the nature of your interaction with the Services, as detailed below. You are not required by law to voluntarily provide us with information. You can always avoid providing us certain Personal Data; however, you acknowledge that it may prevent us from providing you certain Services. In addition, we will always treat Non-Personal Data as Personal Data if we combine it.
THE TABLE BELOW DETAILS THE INFORMATION WE COLLECT AND HOW WE USE IT:
Data we collect from Business Partners and visitors to our Site:
Data we collect from Users:
How We Collect Data
Depending on the nature of your interaction with the Services, StartApp may collect data from you, as follows:
- Provided by you voluntarily – we will collect data if and when you choose to provide us with such data, for example through a registration process, contact us communications, payment process, etc.
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 required under applicable law, we will obtain consent prior to collection of Personal Data, or obligate our Business Partners to obtain such consent, and always offer the choice to opt-out.
For additional information regarding choices you may have with respect to our use of your data, please refer to the Your Choices and Controls section of the Policy.
Cookies and Data Collection by Third Party
When you access or use the Site, we may use industry-wide technologies such as “cookies” (or similar technologies), which store certain information on your device (i.e., locally stored) and which will allow us to customize the Service and content as well as enhance your experience with the Services. The cookies and similar technologies used by us are created per session and may include IDs, as well as your preference, navigation and the session key and allow us to analyse trends, track users’ movements around the Site, 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. For more information about cookies and your controls in this regard, you may review the following links:
- https://support.google.com/chrome/answer/95647?hl=en (Chrome);
- https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
- http://www.opera.com/help/tutorials/security/cookies/ (Opera);
- https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
- https://support.apple.com/kb/PH21411 (Safari); and
- https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge)
We may employ and use third parties’ cookies or other technology to collect information about your online and application usage activities across our Services, as follows:
- Google Analytics: this cookie is placed in order to track and analyse the use of our Services, for internal purposes. To learn more about how Google uses data from our use of Google Analytics Cookies, we recommend you review Google’s policies located at: google.com/policies/privacy/partners. For additional information, please see Google Analytics’ opt-out web tool available at: https://tools.google.com/dlpage/gaoptout.
- To manage Flash cookies, please click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html
Sharing Data with Third Parties
StartApp will not share any Personal Data collected from you with third parties or any of our partners except in the following events:
- Authorized Disclosures.We may disclose your Personal Data to third parties when you consent to a particular disclosure of your Personal Data. Please note that once we share your data with a third party, the data becomes subject to that third-party privacy practices.
- Compelled Disclosures. We will share your data, 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) as well as 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 data, 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.
- Service Providers. We may disclose Personal Data to our service providers so that they can perform requested services on our behalf. These services may include payment processing (such as PayPal), direct marketing, research and analytic, storage s and hosting services, etc. These entities are prohibited from using your Personal Data for any purposes other than providing us with requested services.
- Business Transfers and Affiliated Company. We may share Personal Data, in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale), as well as with our affiliated companies. In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Policy.
- We may share IDs collected by us (as detailed above), for the purpose of operating our business and providing the Services, as well as to calculate payments and detect fraud, security or technical issues in connection with the Services.
- Third Party Partners.We may share Personal Data with our Third-Party Partners, which may use such Personal Data for targeted advertising purposes (among others), as follows:
In the event you do not wish your Personal Data to be shared with such third parties, you may opt-out through the above links OR please refer to the “Your Choices and Controls” section below OR Contact Us and we will be happy to assist you.
- Viewability measurement: StartApp’s SDK includes Open Measurement Software Development Kit by iab TECH LAB (“OM SDK”) for the purpose of verifying that ads were actually viewed. We do not share any Personal Data with IAB or through the OM SDK. For more information about OM SDK, see: https://iabtechlab.com/standards/open-measurement-sdk/
With regards to Non-Personal Data, we may share aggregate or Non-Personal Data with Business Partners and other third parties in accordance with the terms of this Policy. We may store Non-Personal and Personal Data in our servers or our cloud servers, use or share Non-Personal Data in any of the above circumstances, as well as for the purpose of providing and improving our Site and Service, aggregate statistics, marketing and conduct business and marketing analysis, and enhance your experience with the Services.
FURTHERMORE, WE RESERVE THE RIGHT TO USE, DISCLOSE OR TRANSFER (FOR BUSINESS PURPOSES OR OTHERWISE) AGGREGATED AND PROCESSED DATA TO THIRD PARTIES, INCLUDING, INTER ALIA, 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.
Your Choices and Controls
StartApp provides you with the ability to exercise certain choices and controls in connection with our treatment of your data, and according to applicable laws. Depending on your relationship with StartApp (e.g., if you are a User, Business Partner or a visitor of our Site), and depending on the lawful basis according to which the data is processed by us, data protection and privacy laws provide you with certain rights such as to correct, modify, update or delete the Personal Data we collect on you as well as object to the collection or opt-out of the targeting advertising (as detailed below). The principal rights under applicable data protection law in relation to Personal Data are as follows: the right to access information; the right to rectification; the right to erasure; the right to restrict processing; the right to object to processing; the right to data portability; the right to complain to a supervisory authority; and the right to withdraw consent (to the extent applicable). Note that, data privacy and related laws in your jurisdiction may provide you with different or additional rights related to your data, which may also apply.
If you wish to exercise any or all of the above rights, please contact our Data Protection Officer at: email@example.com and let us know which right you wish to exercise.
Where we are not able to provide you with the data you have requested, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisor authority. We reserve the right to request reasonable evidence to verify your identity before we provide you with any such data in accordance with applicable law. In addition, the process of locating and deleting the data may take up to one (1) month (following the receipt of the validation proof we require) in accordance with applicable law.
Opt Out Right
You may easily opt out of certain data collection, sharing process and targeted advertising related to our Services. Please note that even if you opt-out, you may still receive content and advertising, including from StartApp. Opting-out solely provides you with the choice to receive advertisements that are not targeted to you and to control the data collected on you for the purpose of displaying advertisements.
Please read your device specific information to learn how to opt-out:
You may also Contact Us and we will be happy to assist you. Note that once you opt out, part of the Services provided by us might no longer be available and some features may not work if you revoke the data transfer.
Additional means to opt out, depending on your device are available, such as:
- You may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser (as detailed in the Cookie section above).
- You may limit the disclosure of certain data 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.
- If you wish to opt out of interest-based advertising, you may also click here, or if located in the European Union click here. Please note you will continue to receive generic ads.
- Our Business Partners may also provide ways for you to opt out from or limit their collection of data from and about you. Please refer to the privacy policies of 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.
We may send our Business Partners an email or other messages about us or our Services. We may also send our updates or newsletter to individuals who have registered to the newsletter or used our Services. You can remove your Personal Data from our mailing list and stop receiving promotional communications from us by following the unsubscribe link located at the bottom of each communication or by emailing us at firstname.lastname@example.org
Please note that in the event you are our Business Partners, even if you unsubscribe, we reserve the right to send you service-related communications, including service announcements and administrative messages, relating either to your account or to your transactions the Services, without offering you the opportunity to opt out of receiving them unless you terminate and delete your account. If you wish to delete your Account, please contact us at: email@example.com. Note that, even if we will delete your account, we will not delete certain information required under applicable law or otherwise, required for the legitimate purposes of our business. For example, we will not delete any invoices sent to you as we need it for the purpose of managing our financials.
StartApp complies with applicable legislation related to children’s privacy protection, including the US Children’s Online Privacy Protection Act (“COPPA”). Thus, we do not knowingly collect or solicit Personal Data from children, as they are defined under applicable law, and specifically: under the age of 13 years old, if they are located in the US; (ii) under the age of 16 years old, if they are located in the EU; (collectively: “child” or “children”), except as permitted under applicable law. Notwithstanding the above, in any event, we will not knowingly collect Personal Data from children for the purpose of behavioural advertising. If we later obtain actual knowledge that a User is considered as a child under applicable law, and Personal Data was collected (other than as permitted under applicable law) we will take steps to immediately delete its Personal Data. In addition, we request that children will not voluntarily provide us with Personal Data through the Services. If you become aware or have any reason to believe that a child has shared any Personal Data with us, please contact us and we will take steps to ensure that such Personal Data is immediately deleted from our files, to the extent required under applicable law.
Data Security, Integrity and Retention
Your privacy is very important to StartApp and we are committed to protecting your Personal Data 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. For more information on our security measures, please click here.
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.
StartApp also protects User privacy by seeking to minimize the amount of data that we store on our servers in the first place. We retain the Non-Personal Data we collected for as long as needed to provide the Service, carry out our business purpose and to comply with our legal obligations, resolve disputes and enforce our agreements, in accordance and compliance with applicable laws, but in any event, we will not keep the data longer than 24 months in an identifiable form, or as required by law. Other data, such as the IDs are kept for maximum time period of 6 months and some for less than 7 days, all as required to provide the Service and in compliance with applicable laws and legislation.
Further, in the event of a data breach, in which we discover your Personal Data is at risk, or might be at risk, we will notify you through the Services or, if technically possible, by sending you an email.
Transfer of Data
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 of such amendments and your agreement to be bound by the terms therein.
If you have any questions or comments about this Policy, please write to us at:
584 Broadway St. 12th Floor Suite 1206 New York, NY, 10012
You can also contact us via email at: Support@startapp.com.
Data Protection Officer and Dispute Resolution Provider
If you have any requests regarding the data collected under this Policy, including without limitation, requests to remove, delete, amend, modify or transfer the data, please contact our Data Protection Officer at: firstname.lastname@example.org
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.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.