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SERVICES AND WEBSITE PRIVACY POLICY

Applies to: Website visitors or users, Publishers and Advertisers

StartApp Inc. and its Affiliates (“we,” “us,” “our” or “StartApp”) is a mobile advertising and data company that develops, operates, supports and provides its mobile application developers, advertisers and publishers with an advertising platform for the purpose of delivering targeted and personalized advertisements to individuals (“End User(s)”) that download, use or otherwise interact with an app developer or publisher’s app or our Services, as defined below.

This Privacy Policy (“Policy”) describes how we collect use, shares and secure the data provided or collected from visitors of StartApp Website and from advertisers and publishers which are registered to or use our Website or Services (“Customers”; together with the Website visitors: “you” or “yours”), through our various services and features, as follows (which collectively shall be defined hereinafter as the “Services”):

(a)     our websites available at www.startapp.com including its subdomain (“Site”), and any service or feature provided therein;

(b)     the monetization platform for our Customers available at: https://portal.startapp.com/#/signin.

(c)     Mobile app developers or publishers that implement StartApp Software Developer Kit (“SDK”) within their mobile app for the purpose of displaying advertisement.

As our technology enables our Customers to show End Users more relevant advertising that is based on End Users’ interests and behaviours, we collect and use certain data about End Users’ activity and preferences, all as detailed StartApp End User Privacy Policy, available at: https://www.startapp.com/policy/privacy-policy/, and incorporated herein by reference. For more information about StartApp, you may visit our website at: www.startapp.com.

This Policy is an integrated part of the 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/.

StartApp is a controller of your personal data, and processes it pursuant to this Policy.

You hereby agree to the use of: (a) electronic means to consent to and complete this Policy and to provide you with any notices given pursuant to this Policy; and (b) electronic records to store information related to this Policy.

  1. Personal information that you voluntarily provide

(a)        Registration: when you create an account for using the Services, you will be required to provide us with certain information, such as: first and last name, email address and company name, and to choose a username and password.

We may use this information for the purpose of (i) performing our contract with you, provide you with the Services you have requested, and designate your account; (ii) verifying your identity; (iii) sending you information related to the Services and our engagement with you, such as: welcome message, Services updates, tips related to our Service, and applicable invoices; and (iv) sending you marketing and promotional messages, offers and discounts.

(b)        Payment Details: in the event you are our Customer 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. Your payment details data will be used for the purpose of performing our contract with you, i.e., process and provide payments you have to pay or will be entitled to.

We may use third parties’ payment processors services to facilitate and execute payments from you. In such event, collection, process and use of the payment details submitted by you shall be subject to their privacy policies. Credit cards details may be provided only to payment processor(s) which represent and warrant that they are PCI compliant.

(c)        Contact Information: in the event you contact us for support, feedback, meeting set up, complaint or other inquiries, either through an online form available in the Website, by sending us an email or by other means of communications we make available, you may be requested to provide us your contact details such as name, email address, country and/or Customer’s account details (where applicable). We may ask for further information to verify your identity.

We will use this information solely for the purpose of responding to your inquiries and provide you with the support or information you have requested.

(d)        Mailing List & Newsletter Subscription: if you voluntarily subscribe to our mailing List or newsletters through the Website (or otherwise agree to receive our updates and/or content), you may be requested to provide us with your email address and name. You can unsubscribe at any time using the unsubscribe option within the body of the applicable email or rather by contacting us (as detailed below).

We will use this information in order to send you information related to our Services and to keep you up to date regarding new Services, as well as to provide you with tips related to our Services, promotional and marketing emails (offers, events and discounts).

(e)        Social Network Sign In: if you choose to sign in with your social network account (such as Google, LinkedIn, etc.), such network account may provide us with access to certain information about you as stored therein (e.g. full name, e-mail and any other information which you made public).

We will use this information solely for the purpose of providing you the Services you have requested.

(f)         Content Request: if you wish to access or be provided with certain materials such as download a whitepaper, articles or a case study offered by us, you may be requested to provide us with your name, email address, and company name.

We will use this data to provide you with the content and materials you have requested.

(g)        Referral Program: if you are our Customer, and you wish to participate in our Referral Program available at:   https://portal.startapp.com/#/pub/referral/friend-referral, you will be requested to provide us with a third party’s valid email address (i.e., the referee’s email).

We will use this information to send the referee the applicable notification regarding the referral, and invitation to join our Services through the Referral Program (as detailed in the Referral Program Terms and conditions.

In the event you believe one of your contacts provided us with your personal data (e.g., email address) in order to invite you to register through the Referral Program, and you wish to have such information deleted or otherwise updated, please contact us at: website-privacy@startapp.com.

(h)        Recruitment: in the event you are interested in joining StartApp team and wish to submit your CV for the jobs offers posted in our Website, you will be required to provide us your full name, email address, and phone number as well as additional information (i.e., LinkedIn page, etc.). This information can be sent directly to StartApp through email or submitted through an online form on the Website by using our partner COMEET API. For more information on COMEET data collection practices please see: http://support.comeet.co/privacy-policy/

We will use the information you have provided solely to communicate with you, to manage our recruiting and hiring processes, and for compliance with corporate governance and legal and regulatory requirements. If you are hired, the information may be used in connection with employment and corporate management. Note that, your provision of personal information in connection with recruiting is voluntary, and you determine the extent of information you provide us. We do not request or require sensitive personal information (such as: religion, health, sexual orientation, or political affiliation in connection with recruiting).

Other than the above, StartApp does not require its Website users or visitors to provide personal identifiable information to view the Website’s content or to browse the different pages of the Website.

Certain areas, features, frames or sections accessible through the Website may be operated by third parties and are subject to their own privacy policies and practices, not this Policy. In particular, when you provide information (personal or otherwise) through such elements that are operated by third parties, those third parties, and not StartApp, are responsible for the privacy practices associated with such elements. However, those third parties may share the information that they collect from you, with StartApp and StartApp may use such information as described in this Policy.

You may correct or update your personal identifiable information by logging in to your account with StartApp and making the change on your personal information page. If you no longer desire to obtain our services or wish to delete or deactivate your account, you can contact us at support@startapp.com and ask that we will do it for you.

  1. Other information we collect from you when you visit our Website

We will collect and process the following data (or part of it, depending on your interaction with our Services, as a visitor or registered Customer or potential customer), when you visit or access our Website:

Internet protocol address, the type of browser (e.g., Firefox, Internet Explorer), type of operating system, (e.g., Microsoft Windows or Mac OS), domain name of Internet service provider (e.g., Comcast, Verizon or AT&T), web pages visited, websites visited before and after visiting the Website, type of handheld or mobile device used to view the Website (e.g., iPhone, Blackberry), and information in regard of your interaction with the Website (content viewed, accessed or used, amount of time spent viewing certain portions of the Website). We may use third parties to conduct web analytics and similar services with respect to an interaction with our Website.

In addition, when you access or use the Services or use the Website, we may use cookies or web beacons to collect, process and use the above information. Please review Section 9 below for more information about cookies or web beacons used by us.

  1. Use of Collected Information

The information collected may be used for the following purposes:

(a)     To share it with third parties, as detailed in Section 4 (“Sharing Collected Information“);

(b)     To provide you with our Services and the Website’s functionality;

(c)     To reply to your engagement with us;

(d)     To engage you with marketing or operational promotions or messages (including retargeting);

(e)     To improve and customize your experience with our Services and the Website and develop new services, capabilities and features;

(f)      To audit and track usage statistics and traffic flow of our Services and the Website;

(g)     To manage the administrative and operational aspects of our Services and the Website;

(h)     To protect the rights or property of StartApp or third parties;

(i)       To enforce the terms of our engagement with you and the terms of service of the Website and to prevent unlawful activities and misuse of our Services and the Website;

(j)       To comply with any applicable law and assist law enforcement agencies when we have a good faith belief that our cooperation with them meets the applicable legal standards; and,

(k)     To take any action in any case of dispute involving you with respect to our Services and the Website.

In those jurisdictions which require lawful basis for process of personal information: the legal basis for processing of your personal information for the purposes above, other than subsection (d) is to perform the contract with you or our legitimate interests. For the purpose outlined in subsection (d), the lawful basis is your consent, which is granted to us upon your registration to the Service or voluntarily providing your contact details to us.

  1. Sharing Data with third parties

We may share your data (or part of it) in accordance with the following:

(a)     We may share your personal information with sub-contractors or service providers for the purpose of rendering, supporting or enabling part of our Services. These third parties’ services may include payment processing (such as PayPal), direct marketing, research and development, analytics, storage and hosting services, fraud detection, attribution services and security services. Please note that we are not responsible for the privacy practices of these third parties when they engage you directly through our services. Hence, you are encouraged to review their privacy policy or notice.

(a)     If you have breached the terms of your engagement with StartApp or this Policy, abused your rights, violated any applicable law, or in any other case of dispute, or legal proceeding of any kind involving you with respect to your engagement with StartApp or this Policy, your information may be shared with competent authorities and with any third party, as may be required.

(b)     We may share information that we collect or obtain with the relevant authorities, entities or persons if we reasonably believe that we are required by law to share or disclose your information.

(c)     Personal identifiable information may be shared with, or transferred to, our affiliated corporate group entities (entities controlled by, under common control with, or controlling us, directly or indirectly; “Affiliate(s)”), but their use of such information must comply with this Policy.

(d)     Upon bankruptcy, dissolution or other liquidation or insolvency events or in the event of merger, sale or transfer of all or a portion of our assets or shares or other reorganization or reconstruction in our ongoing business, the information that we receive, collect or obtain, as outlined in the preceding sections, may be shared with or transferred to, that respective entity, provided that it will undertake to be bound by the provisions of this Policy, with reasonably necessary changes taken into consideration. Upon such transfer or sharing of information, that entity will assume full and exclusive responsibility for all subsequent use and processing it makes of the information and we will be released from any liability to you, regarding the succeeding entity’s use and processing of the information by it.

(e)     In any case other than the above mentioned in this Policy, your personal identifiable information will be shared with others only if you provide your consent.

In those jurisdictions which require lawful basis for process of personal information, sharing of your data is based on performing our contract with you or on our legitimate interests.

  1. Direct Marketing

We may send you emails 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 yourself 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: support@startapp.com.

Please note that in the event you are our Customer, 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: support@startapp.com. Note that, even if we 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.

  1. Non-personal, aggregated or anonymized data

Non-personal, aggregated or anonymized data, which does not identify you personally, may be collected, processed and used by us in any way, including by posting, disseminating, transmitting, sharing or otherwise communicating or making it available to third parties.

  1. Process of Sensitive Information

StartApp does not require nor does it knowingly or intentionally collect, solicit or otherwise process any Sensitive Information from or about you.

The term “Sensitive Information” may have different meaning in different jurisdictions, and may include: racial, ethnic or communal origin; political affiliations or opinions; religious or philosophical beliefs or other beliefs of a similar nature; intimate affairs or sexual life; financial data, credit worthiness data, financial account, payment card number; criminal record; political parties or trade-union membership; and physical or mental health or condition, health insurance, medical and/or biometric data.

If you become aware or have any reason to believe that you were requested to provide any Sensitive Information, or that StartApp processed any information which may be considered as Sensitive Information, please contact us at website-privacy@startapp.com and we will take steps to ensure that such Sensitive Information will be immediately deleted from our files. Please note that the definition of “Sensitive Information” may not have the same meaning in different jurisdictions.

  1. Children’s Privacy

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 or intentionally collect or solicit personal information 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, or under the age of 16 years old, if they are located in the EU; (collectively: “Child” or “Children”), except as permitted under applicable law.

If we obtain actual knowledge that a user of our Services or visitor of our Website is considered as a child under applicable law, and we processed personal information with respect to that End User (other than as permitted under applicable law) we will take immediate steps to delete his/her personal information. In addition, we request that Children will not voluntarily provide us with any personal information.

If you become aware or have any reason to believe that a Child has shared any Personal Information with us, please contact us at website-privacy@startapp.com and we will take steps to ensure that such personal information is immediately deleted from our files, to the extent required under applicable law.

  1. Cookies and Data Collection by Third Party

When you access or use the Services or use the Website, we may use cookies, web beacons (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, including: store your preferences, analyze trends, track your navigation and movements around the Website and remember your password when you login. Cookies (which may be HTML files, Flash files or other technology) are text files that help store user preferences and activity; “web beacons” (also known as image tags, gif or web bugs) are small pieces of code used to collect data, such as counting page views or promotion views.

We may use both session ID cookies and persistent cookies. Session cookies are used to make it easier for you to navigate the Website. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. We set a persistent cookie for such uses as to store your user name so you don’t have to enter it more than once. Persistent cookies also enable us to track and target the interests of our users to enhance the users’ experience on the Website. If you reject cookies, you may still use the Website, but your ability to use some areas of the Website may be limited.

By visiting the Website and/or using our Services, whether as a registered user or otherwise, you acknowledge, understand and hereby agree that you are giving us your consent to gather information about your use of the Website, through cookies and web beacons.

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:

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: www.google.com/policies/privacy/partners. For additional information, please see Google Analytics’ opt-out web tool available at:  https://tools.google.com/dlpage/gaoptout.
  • Full Story: this cookie is placed in order to assist us in operating our marketing activities.  To learn more about Full Story privacy practices, we recommend you review its privacy policy available at: https://www.fullstory.com/legal/privacy/.
  • Zendesk: we use Zendesk services in order to assist us in operating our customer support. To learn more about Zendesk privacy practices, we recommend you review its privacy policy available at: https://www.zendesk.com/company/customers-partners/privacy-policy/
  • Incapsula: we use Incapsula services in order to secure our Website and Services.  To learn more about Incapsula privacy practices, we recommend you review its privacy policy available at: https://www.incapsula.com/privacy-policy.html
  1. 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 registered advertiser or publisher or a visitor of our Website), 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 us at: website-privacy@startapp.com, [GANIT] and let us know which right you wish to exercise. 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 30 days (following the receipt of the validation proof we require) in accordance with applicable law.

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 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.
  1. Data Security

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.

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.

  1. Data Retention

If your engagement with StartApp as a Customer is terminated, we will continue to use your personal data in accordance with the following:

(a)     We will send you marketing materials and promotions unless you unsubscribe from our email list, exercise any relevant right pursuant to Section 10 above (“Your Choices and Control”), or otherwise send us notice to website-privacy@startapp.com, asking to unsubscribe.

(b)     We will use your contact details for accounting, invoicing, tax and other legal or financial purposes for a period of 7 years as of end or year of termination. Such usage is based on our legitimate interests.

Following that 7 years period, we will anonymize your personal data by deleting your name, email address, and mobile number. If any other information may identify you personally, please contact us at: website-privacy@startapp.com, and we will delete such data as well.

  1. Transfer of data outside your territory

We may store or process your personal data in the United States or in other territories. If you are a resident of the European Economic Area (“EEA“) we will take appropriate measures to ensure that your personal data receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where transfer of your Personal Data requires your consent, then your consent to this Privacy Policy includes your express consent for such transfer of your data.

  1. Changes to The Policy

This Policy may be updated by us from time to time. Substantial changes will take effect 30 days from update. Other changes will take effect 7 days from update. If the Policy is amended to comply with legal requirements, the amendments will become effective immediately. The most up-to-date Policy as well as any updated to this Policy will be published and will be available in the following link: https://www.startapp.com/startapp-website-privacy-policy/. We encourage you to review the Policy periodically to ensure that you understand how we collect, process, use and share your information through StartApp Network.

  1. 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: website-privacy@startapp.com.

  1. Data Protection Officer

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: website-dpo@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.

Last update: February 21, 2019