The term, “Personal Data”, as used in this Policy means information relating to an identified or identifiable natural person.
The term, “processing”, as used in this Policy means any action taken in respect of the data.
Any undefined capitalized terms shall have the meaning given to them in AppCharge Terms and Conditions. We may change this Policy from time to time in order to keep you apprised of our data collection and use practices. We encourage you to regularly visit and review this Policy to stay informed of such practices.
Table of Contents
- The Personal Data we Collect and How we use it
- When you access and use our Services, such as our webstores
- When you visit and use our Site (automatically collected data)
- When you access any of our Services through your social media accounts as a potential customer
- When you contact us (including for support)
- When you apply for an open position we offer
- When you make a payment or enter payment information on the Services
- When you create an account and become our customer
- How (and with whom) we Share Personal Data
- Cloud and Hosting Services
- Law Enforcement or Other Government Entities
- With your Consent
- Mergers and Acquisitions
- Additional Information on our Service Providers
- How Long we Retain Personal Data
- Your GDPR Rights
- Transfers of Personal Data to other Countries outside the EU or EEA
- Your California Privacy Rights
- Disclosure of Direct Marketing Practices (“Shine the Light”)
- Removal of Public Information of Minors
- California Do Not Track Notice
- Third Party Websites, Services & Data Collection
- User Content – Safety and Report
- Personal Data of Children
- Anonymous Information
- Our Contact Information
1.The Personal Data We Collect and How We Use It.
We collect and receive Personal Data from outside our company and affiliates, such as from users of our products and services as described in the table below. Certain Personal Data is collected automatically, while other Personal Data is provided by you voluntarily, for example, when you contact us. The description in the table may be supplemented by additional information in other parts of this Policy. For example, you may find for more information on third-parties to whom your information may be transferred in Section 2 below.
|When we Collect Data||Type of Personal Data we Collect||Purposes of Processing the Data||Retention Period (How long we store the data)*||Legal Basis under the GDPR||Third Parties with Whom We Share your Personal Data**||Consequences of not Providing the Personal Data|
|1.1 When you access and use our Services, such as our webstoresddd||-Google and Apple Advertiser IDs|
-transactions of -purchases
-user behavior (including purchases, login, heatmap and all other activity in the webstore).
|-operating, providing, maintaining, protecting, managing and customizing our Services; |
-analysis of traffic, user and visitor;
-improving our products and services;
-Legitimate interest (e.g. essential cookies)
|You cannot access and use the Services;|
|1.2 When you visit our Site|
(automatically collected data)
-Placement of cookies, including third party cookies
-Information about your web browser and operating system
-Referring URL or source (which referred you to our Site)
-Other information automatically sent by your browser and contained in HTTP Headers
-Site activity (including what you click on, the date and time of your visit).
|-protecting the security of the Site;|
-enable site functionality
-identify unique users, track user activity on the site, and unique website views.
-improving and providing you our products and Services;
|5 yers||-Your consent|
-Legitimate interest (e.g. essential cookies)
|1.3 When you contact us (including for support)||-Full name|
-Any other information you provide
|-Verify your identity, process your request and respond to or contact you regarding your request; |
-Present this information to you as part of your history
-To display and contact you with information that is relevant to you in the future, and to assist you with further requests for support;
-Improve our customer support and communication practices;
-Our legitimate interest.
|We may not be able to provide you support or respond to your request.|
|1.4 When you apply for an open position we offer||-CV|
-Any other information you provide
|Verify your identity, process your request and respond to or contact you regarding your request;||5 years||Your Consent||We will not be able to answer and process your request.|
|1.5 When you make a payment or enter payment information on the Services||-First Name, Last Name|
-Confirmation of payment;
-Payment confirmation and transaction ID number (from Apple or Google);Device model (for the device on which the transaction was completed)
|Confirm that you have paid amounts due and what was paid for so we know to provide you the applicable features or services;|
Protecting the security of the Services, as well as our and third parties’ rights (subject to applicable law requirements).
|180 days||-Your Consent|
-Performance of our contract (Terms of Service) with you.
|-Apple ||We may not be able to provide you with some of the Services.|
|1.6 When you create an account and become our customer||-Full name|
-User behavior: Heatmap
-Device Identifiers, types and configuration.
|To contact you regarding our Services for you or your company;|
To establish and maintain a business relationship with you;
To send you information about our products and services.
|As long as the account is active and for 180-days after deletion of account, in order to allow for account restoration or address user questions.||-Your Consent; |
|We would be unable to contact you.|
**Please see Section 2.7 below for more information about third parties listed in this column.
2. How (and with whom) we Share Personal Data
In addition to any methods or third parties with whom we may share your Personal Data described above, we share Personal Data in the following manner:
Cloud and Hosting Services.We use cloud storage providers to host the Services and store all information we collect. We currently engage Amazon Web Services, Mongo and Google, LLC (or one of its affiliates), for such services and in addition to the third parties listed in Section 1 above, copies of all data we collect are stored on their servers.
Law Enforcement or Other Government Entities.Where required by law or government or court order, we will disclose Personal Data relating to you to the extent we believe we are required by law.
With your Consent.In the event that you have requested or have consented to the transfer of Personal Data relating to you to a third party (such as by checking a box to signify your agreement) we will transfer Personal Data to the relevant third party.
Disputes and Legal Advice.In case of any dispute or request with, by or concerning you, we may disclose Personal Data relating to you with our legal counsel, professional advisors and service providers, the relevant court or other tribunal and other third parties as needed in order to resolve the dispute, defend ourselves against any claims, or enforce our rights.
Mergers and Acquisitions.In the event that we, or a part of our business, are sold to a third party, or if we are merged with another entity, or in the event of bankruptcy or a similar event, we will transfer information about the relevant portions of our business as well as relevant customers and users and other personal data, to the purchaser or the entity with which we are merged. We may also transfer personal data to a potential acquirer, their legal counsel or service providers as part of an evaluation or due diligence review of our company in anticipation of an investment, acquisition or merger, though such transfers do not typically include personal data and are subject to obligations of confidentiality.
Affiliates.We share personal data with our affiliates, who assist us in processing personal data and providing our Services.
Additional information on our Service Providers (listed in Section 1). To help you understand where data about you is transferred, here is more information about the service providers listed above whom we engage to process Personal Data that we collect. Where such service providers have made available information about their data security or processing practices which we think is relevant to you, we have provided links to such information. We take no responsibility for information found on their websites, including, without limitation, whether it is accurate or up-to-date.
- Amazon Web Services is a provider of cloud services, which we used to host the backend of our Services and store data that we collect. For more information about how Amazon Web Services handles data stored on behalf of its customers like us, visit https://aws.amazon.com/compliance/data-privacy-faq/.
- Apple, inc. provides us login features which allows us to receive information in connection with your Apple profile in order to provide you services in our stores. When you use the Services, Apple receives information about your use of the Services. You can find out more about how Apple uses Personal data at: https://support.apple.com/en-us/HT203027.
- Facebook, Inc., provides us login features known as “Facebook Connect”. This allows us to receive information in connection with your public Facebook profile in order to provide you services in our stores. When you use the Services, Facebook receives information about your use of the Services. You can find out more about how Facebook uses Personal data at https://www.facebook.com/full_data_use_policy.
- Google LLC and its affiliates provide us with storing services, analytical tools and manage relationship with our customers. You can read more about Google’s policies in connection with data received from its customers at: https://privacy.google.com/businesses/compliance/.
- HubSpot – provides us with data storage and management services. To learn more about how HubSpot collect and process data, please visit: https://legal.hubspot.com/privacy-policy.
- LogRocket – provides us with analytics, such as, browser data and heatmap) and support tools for the development and maintenance of our Services. You can learn more about how LogRocket uses Personal data at: https://logrocket.com/privacy/.
- MailChimp – provides us with email distribution services. For more information about how MailChimp handles data we transfer to it visit: https://www.mongodb.com/legal/privacy-policy.
- Mongo Atlas – provides us with data storage services. For more information on how Mongo Atlas process and protects data, visit: https://www.mongodb.com/legal/privacy-policy.
3. How Long We Retain Personal Data
We may store Personal Data for longer periods of time than stated in Section 1 above: (i) where we believes we are required to do so to comply with laws or in connection with legal proceedings; (ii) to resolve disputes; (iii) to enforce agreements between us and others; (iv) when the information is related to a potential or actual legal dispute.
4. Your GDPR Rights.
Subject to certain exceptions and exclusions, the following rights apply to individuals who are located in an EU member states or otherwise protected by the EU General Data Protection Regulation (“GDPR”), as further described below. If you are such a person, then:
- Right of Access. You may request that we confirm to you whether or not we store Personal Data about you and to receive a copy of the Personal Data we maintain about you and information about: (a) the purposes of the processing of the Personal Data; (b) the categories of Personal Data being processed; (c) the names of the recipients or the categories of recipients to whom the Personal Data have been or will be disclosed, in particular recipients in third countries or international organizations; (d) if possible, the period we believe we will store the Personal Data, or the criteria we use to determine that period; (e) the sources of the Personal Data, if not collected from you; and (f) whether we use automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.
- Right to Rectify. You may request that we correct any Personal Data about you that we maintain that is incorrect. Depending on the purpose for which the data is used, you may also request to complete incomplete Personal Data we maintain.
- Right to Erasure (“Right to be Forgotten”). You may request that we erase or suppress Personal Data that relates to you in the following cases: the data is no longer needed by us; the data was collected and is used on the basis of your consent and you withdraw that consent; when you have a right to object to our use of the data (as described below under, “Right to Object”); we are not lawfully processing the data; or we are otherwise required by law to delete the data. However, there may be circumstances in which we may retain your data or we may refuse your request, for example, when we review the data to defend ourselves or make legal claims or exercise are own rights. In addition, this right may not apply to the display or access of your Personal Data outside of the European Union.
- Right to Restrict Processing. You may request that we restrict our use or processing of your Personal Data if: you claim the Personal Data is inaccurate, during the time we investigate your claim; our processing of the Personal Data was unlawful; we no longer require the Personal Data; we processed the Personal Data for our legitimate interests and you object to this use (as you are permitted to do under Article 21(1) of the GDPR), during the time that we investigate whether our legitimate interests override your request. However, there may be circumstances in which we are legally entitled to refuse your request.
- Right to Data Portability. You may request that we provide you with your Personal Data that we process based on your consent or to fulfill a contract with you or that we process using automated means, in a structured, commonly used and machine-readable format, and to transfer your Personal Data to another entity or have us transfer it directly to such entity.
- Right to Object. You may, based on reasons specifically relating to you, object to our processing of your Personal Data, when: (i) the data is used for our legitimate interests and our interests in processing the data does not override your interests, rights and freedoms and we do not require use of the data for the establishment, exercise or defense of our legal claims or rights; and (ii) we use the data for direct marketing purposes or profiling for direct marketing purposes.
- Right to Object to Automated Decision Making. You may request that you not to be subject to a decision based solely on automated processing, including profiling, when the decision produces legal effects concerning you or significantly affects you.
- Right to Withdraw Consent. Where we process Personal Data relating to you based on your consent (such as by clicking a check box adjacent to a statement of consent), you may withdraw your consent and request that we cease using your Personal Data for the purpose for which you have your consent, or altogether, depending on the situation.
- Right to Make a Complaint. You may file a complaint regarding our practices with the data protection authority in your place of habitual residence, place or work, or the place of the alleged infringement. For a list of data protection authorities in the European Economic Area, please see here: https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
You can exercise your rights that apply to us by contacting us by email at email@example.com. We may be permitted by law (including the GDPR and local national laws) to refuse or limit the extent to which we comply with your request. We may also require additional information in order to comply with your request, including information needed to locate the information requested or to verify your identity or the legality of your request. To the extent permitted by applicable law, we may charge an appropriate fee to comply with your request.
5.Transfers of Personal Data to other Countries outside the EU or EEA
We transfer Personal Data we receive in or from the European Union (and other locations) to the following countries outside the EU and European Economic Area. If Personal Data from the EU is transferred outside the EU to our affiliates or to third-party service providers, to countries which the European Commission has not determined to adequately protect Personal Data, we take steps to ensure that such Personal Data receives the same level of protection as if it remained within the EU. This includes entering into data transfer agreements and using the European Commission approved Standard Contractual Clauses.
- We are located in Israel. As of the date of this Policy, the European Commission has determined that the State of Israel adequately protects Personal Data. (A list of countries which the European Commission has determined to adequately protect Personal Date can be found, as of the date of this Policy, here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en).
- The United States, where Amazon Web Services, Google, Facebook. Twiter, LinkedIn, LogRoket, Leadfeeder, HubSpot, MailChimp and Mongo Atlas store information on our behalf.
If you are an individual protected by the GDPR, you may contact us in order to obtain additional information regarding the basis for the transfer of Personal Data relating to you to countries outside the European Economic Area. Please note that information or copies of documents we may provide to you in connection with such requests may be limited or redacted in order to protect the rights of third parties or to comply with contractual obligations we may have (such as obligations of confidentiality).
6.Your California Privacy Rights
If you are a California resident you have the right under California law to make certain requests in connection with our use of Personal Data relating to you, as described below. To make such a request, please contact us by email at firstname.lastname@example.org. Please note that certain exceptions may apply.
- Disclosure of Direct Marketing Practices (“Shine the Light”). Under California Civil Code Section 1798.83, one time per year you may request the following information regarding our disclosure of your Personal Data to third parties for their direct marketing purposes: a list of the categories of the personal information disclosed to such parties during the preceding calendar year, the names and addresses of such third parties, and if the nature of the parties’ businesses is not clear from their names, examples of the products or services marketed by such third parties. This right only applies if our relationship is primarily for your personal, family or household purposes and related to the purchase of our products and services.
- Removal of Public Information of Minors. If you are under the age of 18 and have an account with us, under California Business and Professions Code Section 22581, you may request the removal of content or information you have publicly posted on our services that is identified with you or your account. Please be aware that certain exceptions may apply and we may not be able to completely remove all such information.
7.California Do Not Track Notice.
We do not track individuals’ online activities over time and across third-party web sites or online services (though we do receive information about the webpage you visited prior to access our websites, products and services such as our Site, the App, and advertisement landing pages. We do permit third-parties to track individuals’ online activities on our Site and App, this includes Google and Facebook which provide us with the analytics and tracking services described above. We do not respond to Web browser “do not track” signals or similar mechanisms. You can find out more information about do not track signals at: http://www.allaboutdnt.com/.
8.Third Party Websites, Services & Data Collection
Our Services may contain links to other websites, products or services offered by third parties (“Third Party Services”). This Policy does not apply to data collected by or on behalf of such third parties, whose privacy practices may differ from ours and who are not under our control. We are not responsible for the actions of such third parties or their data practices. Please review the privacy policies of any such third parties before you interact with them or provide them with Personal Data.
9.User Content – Safety and Report
Some of our Services may allow users to upload User Content. AppCharge has a strict policy regarding forbidden behavior, which you can find in our Terms and Conditions. If you feel like a user is in breach of such terms, please contact us immediately at email@example.com . Please provide as much details as possible, including a copy of the underlying material, the location where we may find it, and the reason such User Content should be removed.
10.Personal Data of Children
Our Services are not intended for, and we do not knowingly collect Personal Data from persons under the age of eighteen (18). If you believe that a person under the age of eighteen (18) has provided us with Personal Data, or if we have received the Personal Data of such person, please contact us at firstname.lastname@example.org.
We do not treat information we collect or receive which is not or cannot reasonably be connected to any particular person or which is anonymized or aggregated such that it can no longer be connected to or used to identify any particular person as “Personal Data”, even if it was originally linked to or stored with Personal Data. Such anonymous information is not subject to this Policy and we may use it for a variety of purposes, may share it with third parties or even publish it for any reason.
12.Our Contact Information
For inquiries regarding this Policy, you may contact us as follows:
Ahad Ha’Am Street 35, Tel Aviv-Yafo,