Last Updated on July 1st, 2020
We reserve the right to change this Policy at any time. We will notify you of any changes to this Policy by sending notice to the primary email address specified in your account. Significant changes will go into effect thirty (30) days following such notification. Non-material changes or clarifications will take effect immediately. You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Policy means that the collection, use and sharing of Customer Data (defined below) is subject to the updated Policy.
What Information Do We Collect?
When you use our Services, the following end user information may be received and processed by us (collectively, “End User Data”):
“End User Account Information”: this refers to name, email address, and date of birth, as well as any social media account information that the end user links to the Services, and any other information the end user otherwise provides.
“Technical Information”: this refers to technical information related to an end user’s mobile device or computer, such as: browser type, device type and model, CPU, system language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier.
“Technical Identifiers”: this refers to various unique identifiers that generally only identify a computer, device, browser or application. For example, IP address (which may also provide general location information), Android ID (in Android devices); advertiser ID, or any user ID issued by you and other similar unique identifiers.
“Usage Information”: this refers to information relating to end user actions, such as clicks, game interactions, events, and other actions that you choose to measure and analyze within the Services.
“Third Party Information”: this refers to information made accessible or provided by Third Party Services (defined below), and may include information regarding user preferences, campaign performance, and other marketing data.
We may also collect any information you (including your representatives or employees voluntarily submit to us), such as registration information you provide to us to use the Services, including your name and email, billing email, and the contact details of your employees and representatives who are using the Services (including name and email address) (“Registration Data”).
Registration Data and End User Data is collectively referred as “Customer Data”.
How Do We Collect Information?
We will only collect and process information where we have lawful bases. With respect to the Customer Data, lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the Services you have requested)), and, in some instances, for “legitimate interests” in the applicable jurisdiction.
We collect Registration Data when you create an account or contact us, and information when you access or use our Services.
We collect End User Data:
When you integrate or direct us to deploy our SDKs, APIs, or other products; and
From third party services that are used by you, or at your direction, in connection with the Services (“Third Party Services”), for example, services for data visualization and end user marketing outreach.
You may direct us not to collect End User Data by implementing end user opt-in or opt-out features in our SDKs, APIs, and other products.
Partial Opt-Out: If a partial opt-out is implemented, we will not collect Technical Identifiers or other identifiable data.
Full Opt-Out: If a full opt-out is implemented, we will not collect any attribution End User Data, until such end user consents via opt-in to such collection.
Deletion Request: If a deletion request is submitted by you pursuant to a verified request by an end user, we will provide reasonable assistance to delete all End User Data associated with such end user, provided that we may retain certain End User Data as permitted by applicable law.
How Do We Use the Information We Collect?
We use Customer Data we collect to:
Deliver and improve the Services and your overall user experience. Such Services may include data analytics, live ops, and marketing campaigns.
To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
To link or combine user information with other information.
To compare and verify information for accuracy and update our records.
Email, text, message, or otherwise contact you with information and updates about us and the Services.
To respond to your comments and questions and provide customer service.
To send you information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
Do We Share Customer Data?
We do not rent, sell, or share Customer Data with other people or non-affiliated third parties except with your consent or as necessary to complete any transaction or provide any service you have requested or authorized.
To provide the Services, we may provide limited access to Customer Data to the following third parties:
Third Party Services: We will share End User Data with Third Party Services (defined above) that you integrate (or direct us to integrate) with the Services.
For example, this may include: Sendgrid, PowerBI, Tableau, Onesignal, Braze, XtremePush, AppsFlyer, and similar providers.
Affiliates: We may share Customer Data with our affiliates and/or subsidiaries.
We may also transfer Customer Data to a third party as a result of a merger, acquisition, reorganization or similar transaction; when required by law or to respond to legal process; to protect our customers; to protect lives; to maintain the security of the Services; and to protect the rights or property of Company. In such event, and to the extent legally permitted, we will notify you and, if there are material changes in relation to the processing of your Customer Data, give you an opportunity to consent to such changes.
Protection of Company and Others
How Do We Use Tracking Technologies?
How Do We Secure Your Customer Data?
We may store Registration Data that are necessary to enable us to operate effectively and deliver our services to you. We store, at your direction, End User Data in the consolidated data warehouse in your systems, as part of providing the Services to you.
We take reasonable steps to protect Customer Data against unauthorized access, alteration, disclosure, misuse, or destruction. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. Because End User Data is stored in your systems and your representatives may have access to such End User Data, the safety and security of your Customer Data also depends on you.
Choices Regarding Customer Data
Under the laws of certain jurisdictions, when processing End User Data in connection with the provision of Services to you, we may be deemed a ‘data processor’ while our customers are deemed ‘data controllers’.
The laws of certain jurisdictions may provide End Users with various rights in connection with the processing of End User Data, including:
The right to withdraw any previously provided consent;
The right to access certain information about you that we process;
The right to have us correct or update any personal information;
The right to have certain personal information erased;
The right to have us temporarily block our processing of certain personal information;
The right to have personal information exported into common machine-readable format;
The right to object to our processing of personal information in cases of direct marketing, or when we rely on legitimate interests as our lawful basis to process your information; and
The right to lodge a complaint with the appropriate data protection authority.
Where we are deemed a data processor, End Users should contact you, our customer, to pursue any such legal data subject rights. We will cooperate with our customers to support and comply with any such data subject rights requests.
Where we are deemed a data controller, your or your End Users may exercise your/their rights by contacting us at: firstname.lastname@example.org. We will respond to your requests within a reasonable timeframe. Please note these rights may be limited in certain circumstances as provided by applicable law.
Children Under 16
The Services are not directed to individuals who are under age of sixteen (16) and we do not solicit nor knowingly collect Customer Data from children under the age of sixteen (16). If you believe that we have unknowingly collected any Customer Data on from someone under the age of sixteen (16), please contact us immediately at email@example.com and the information will be deleted.