1. Interpretation and Definitions
Unless otherwise stated in the context, the following terms have the following meanings, and they shall have the same meaning regardless of whether they appear in singular or in plural.
“Business”, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers’ personal information and determines the type of information collected and the purposes and means of the processing of this information, either on its own or in conjunction with other parties.
“Company” (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to:
Gladsaxevej 342, 2860 Soeborg
“Data” is any information that relates to a User of any of Our Services included in My.Appvestor
“Platform” or “Service” refers to the My.Appvestor platform, owned and serviced by Appvestor ApS, and all of the included services available.
“Sale”, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal information to another business or a third party for monetary or other valuable consideration.
“Service Provider” means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service
“Usage Data” refers to data collected automatically, either generated by the End-user of the Service or from the Service infrastructure itself.
“You” means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Services, as applicable. You can be referred to as the Data Subject or as the User as You are the individual using the Service.
2. Data Collection and Processing
Appvestor collects information about You when You register for an account on the Appvestor Platform or otherwise provide Appvestor directly with any information.
2.1 Types of Data Collected
2.1.1 Technical Information
While using the Appvestor Platform You may be asked to provide Appvestor with some necessary technical information. Technical information may include, but is not limited to: IP-address, Country, Usage Data, and Publisher ID/Business ID from Your Google Account so the Services can be provided to You. This collected information is required for Appvestor to verify that You and Your account(s) are accurately registered.
2.1.2 Other Data
In order for You to register an account on the Appvestor Platform, You must provide Your name, email address, and company affiliation. This information is required to authenticate Your identity and app, and for Appvestor to provide You with the services on the Platform. With your explicit consent Appvestor may also collect and make use of Your Publisher Identifier/Business Identifier connected to Your Ad Networks account(s) and may access and use the information related to Your account. You can withdraw Your consent at any time.
Furthermore, Appvestor may with your explicit consent make use of Your email address to contact You with marketing and promotional communications. You can withdraw Your consent at any time.
3. Use of Your Data
Appvestor may use Your Data for the following purposes:
- To provide and maintain the Services, including monitoring the usage of the Platform Service for the purpose of improving the technical functionalities.
- To contact You: To contact You through electronic communication, such as via email. Without your consent such contact will only be to inform of updates related to the Services technical functionalities.
- To manage Your requests: To attend to and manage a request from You on e.g. the deletion of Your account and your rights as a data subject in accordance with the General Data Protection Regulation.
4. Retention of Your Data
Appvestor will process and retain anonymized Usage Data for analysis purposes. Data that has not been anonymized will be retained until the purpose of use is achieved or You choose to have it deleted.
Appvestor will however delete information related to the services within one month after 6 months of minimum or no activities in the Service and only retain data necessary to comply with the Danish Law on Accounting.
Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
How long specific personal data is retained depends on the purpose for its use, however, we will delete your personal data in accordance with applicable law. We will regularly evaluate that the processing is still valid and correct – also in light of any change that may have occurred in regard to the purpose of the processing or the processing itself.
5. Legal Basis for the Processing of Your Data
Appvestor processes personal data to pursue Our legitimate interest in managing Our business – including being able to handle contracts and purchases of various products and licenses for Our business and to improve, develop and market Our Services, and comply with Our legal obligations. The legal basis for Our processing is thus the following articles in the general data protection regulation:
- Article 6 (1), litra a, according to which personal data may be processed with explicit consent.
- Article 6 (1), litra b, according to which personal data may be processed if this is necessary to fulfill a contract.
- Article 6 (1), litra c, according to which personal data may be processed if this is necessary to comply with a legal obligation.
- Article 6 (1), litra f, according to which personal data may be processed if this is necessary to pursue a legitimate interest unless the interests of the data subject precede this.
Note: Because We process Your data partly on basis of Article 6 (1) litra f, (legitimate interests) You may in certain cases object to Our otherwise lawful processing of Your personal data if You find that Your interests in not having Your data processed exceeds Our legitimate interests in processing Your data, cf. article 21 in the general data protection regulation. See further below on Your rights under the data protection regulation.
6. Transfer of Your Data
Your personal data may be processed in any place where Our Service Providers are located. It means that this information may be transferred to – and maintained on – servers located outside of Your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of Your jurisdiction.
If Your data is transferred to a country outside the EU/EEA, and if the country in question has not been approved by the European Commission as providing adequate protection (See list of adequacy decisions here) Our data transfers will be based on Standard Contractual Clauses (SCC) also approved by the European Commission.
7. Other Disclosure of Your Data
7.1 Law Enforcement
Under certain circumstances, Appvestor may be required to disclose Your Data in accordance with law or in response to valid requests from public authorities (e.g. a court or a government agency). Appvestor may also disclose information associated with You, as well as contact information to third parties if required by law. Appvestor will comply with all applicable data protection provisions, including section 5 of the Danish Act on Personal Data.
7.2 Opt-Out from Data Collection and Inquiries
You have the right to ask Appvestor not to continue the processing of Your personal data. You can exercise this right to prevent processing by contacting Appvestor at firstname.lastname@example.org
The Services may present and contain links to and from the websites of partners and affiliates. If You follow a link to any third-party websites, please note that these websites have their own privacy policies and that Appvestor does not accept any responsibility or liability for these policies. You may check such policies before submitting any personal data to such websites at Your own discretion.
8. Security of Your Data
The security of Your Data is important to Us.
We have implemented the appropriate technical security measures to ensure data protection in all contexts, also taking into consideration the category of the Personal Data that We process. We have further ensured contractual-based instructions to Our Service Providers regarding necessary security measures to supplement the Standard Contractual Clauses approved by the European Commission.
10. Contact Us
For Users Within the European Economic Area (EEA)
Appvestor undertakes to respect the confidentiality of Your Data and to guarantee You can exercise Your rights.
- Access Your Personal Data and update or delete the information We have on You. Please contact Us to assist You.
- Correct the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
- Object to the processing of Your Personal Data. This right exists where We are relying on legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to Our processing of Your Personal Data on this ground. You also have the right to object to where We are processing Your Personal Data for direct marketing purposes.
- Erasure. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
- Request the transfer of Your Personal Data. We will provide to You, or to a third party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
- Withdraw Your consent. You have the right to withdraw Your consent on using Your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.
You may exercise Your rights of access, rectification, cancellation, and opposition by contacting Us. You can exercise Your rights by contacting Appvestor at email@example.com. Please note that We may ask You to verify Your identity before responding to such requests.
You have the right to complain to the Danish Data Protection Authority about Our collection and use of Your Personal Data. For more information You can contact Datatilsynet at:
Carl Jacobsens Vej 35, DK 2500 Valby
Telephone: + 45 33 19 32 00
For Users Within California (CCPA/CPRA)
Categories of Personal Information Collected, Disclosed, or Sold
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer.
Please note that the categories and examples provided are those defined in the CCPA. Certain categories of personal information will only be collected if You provide such personal information directly to Us.
- Identifiers: A unique publisher identifier, business identifier, Internet Protocol address, email address, name, account name, or other similar identifiers.
- Internet or other similar network activity: Interaction with Our Service.
Appvestor only collects and makes use of IP-address, Country, Usage Data and the Publisher ID/Business ID. Documentation on Your consent entails a unique ID, which is generated when You register for an account.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from You and Your device when You use the Appvestor Platform.
Use of Personal Information
We may use or disclose personal information, We collect for “business purposes” or “commercial purposes” (as defined under the CCPA). For more details on how We use this information, please refer to the “Use of Your Data” section. When We disclose personal information for a business purpose or a commercial purpose, We will enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except for performing the contract.
Sale of Personal Information
As defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for valuable consideration. This means that, for example, a sale can happen whenever an application makes statistical analyses on the traffic or views.
Opt-Out of Sale of Personal Information
You have the right to opt out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, We will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.
Your Rights Under the CCPA/CPRA
The CCPA/CPRA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:
- The right to notice. You have the right to be notified of which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
- The right to request. Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes, and share of personal information. Once We receive and confirm Your request, We will disclose the information We have on You.
- The right to say no to the sale of Personal Data (opt-out). You have the right to instruct Us to not sell Your personal information. To submit an opt-out request please contact Us.
- The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and instruct Our Service Providers to delete) Your personal information from Our records, unless an exception applies. We may deny Your deletion request if retaining the information is deemed necessary for Us or Our Service Providers.
- The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer rights.
- The right to correct inaccurate personal information. You have the right to request Us to correct any information about You that may be inaccurate.
- The right to limit the use and disclosure of Your sensitive personal information. You have the right to request We limit the use of Your sensitive personal information.
Our Services do not address anyone under the age of 18.
Exercise Your CCPA/CPRA Rights
In order to exercise any of Your rights under the CCPA/CPRA, and if You are a California resident, You can contact Us at: firstname.lastname@example.org
Your request to Us must:
- Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information, or that You are an authorized representative.
- Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it.
We cannot respond to Your request or provide You with the required information if We cannot:
- Verify Your identity or authority to make the request.
- Confirm that the personal information relates to You.
For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.
PIPA – For users in South Korea
Deletion of Your Data
Transfer of Your Data
|Name of Party (contact information)
|Purpose of Transfer
|Date and Method of Transfer
|Amazon Web Services (aws-EUemail@example.com)
|To host data
|Data is transmitted through information network when You use the Service
|Until You choose to delete data or the agreement term with Service Provider expires.
|For analysis and maintenance purposes
|Data is transmitted through information network when You use the Service
|Until You choose to delete data or the agreement term with Service Provider expires.