Effective Date: December 16, 2019
This Privacy Policy covers the information practices of any website that links to this Privacy Policy (severally and jointly, the “Site”) and is operated by YouAppi Inc. (“YouAppi”, “we”, “us” or “ours”) or its affiliated companies, and the advertising services (the “Services”) that YouAppi provides to its supply and demand partners.
YouAppi believes strongly in protecting the privacy of information entrusted to us. We acknowledge that you may have privacy and security concerns with respect to the information we collect, use, and disclose to third parties for the purpose of allowing us to offer and provide our products and services, so we have provided this Privacy Policy to explain, in as clear and plain language as possible, how we collect and use information. You will also find an explanation of certain rights you have (see Section 6 (Your Rights)) in respect of your Personal Information.
In this Privacy Policy, Personal Information is any combination of information, in the possession of or likely to come into the possession of YouAppi, that can be used to identify, contact, or locate a discrete individual (“Personal Information”). Personal Information includes any expression of opinion about an individual. Information that does not identify a discrete individual (such as aggregated statistical information) is not Personal Information.
Please read this Privacy Policy carefully, before using the Site or the Services, so you can fully understand our practices in relation to Personal Information, before we begin processing your information.
This Privacy Policy explains:
The information gathered by YouAppi from the Site is either information voluntarily supplied by Site users or tracking information gathered as users navigate through the Site. In these instances, YouAppi is considered a data controller of this information. In addition, when you use the Services as a demand partner or supply partner, YouAppi collects Personal Information about your end users in order to provide you with the Services. Please note that you are not required by law to provide us with any such Personal Information. In collecting this Personal Information and providing you with the service, YouAppi acts as a processor of this information on your behalf.
(I) Information voluntarily provided by you on the Site.
When using the Site, you may choose to provide us with information to help us serve your needs. The Personal Information that we collect will depend on how you use the Site. For the purposes listed below, YouAppi acts as a data controller and processes the information on the basis of performance of a contract with you.
We will retain your Personal Information for the amount of time necessary in order to process your inquiries and respond to your requests. If we have not received a communication from you within 9 months, or you have asked to delete your Personal Information, we shall immediately delete records of your Personal Information.
To the extent that you are using the Services, we will store your information for the period in which you have an account with us to provide you with the Services. After you close your account, we will continue to retain and use your Personal Information only to the extent required by applicable law or auditing requirements.
(II) Tracking Information when users navigate the Site.
As you navigate this Site, we also use commonly-used information-gathering tools, such as cookies and web beacons to operate the Site and provide you with certain features and functionalities. These tools collect standard information from your web browser (such as browser type and browser language), your Internet Protocol (“IP”) address and the actions you take on the Site (such as the web pages viewed and the links clicked). The legal basis for processing this information is for the performance of a contract with you and our legitimate interest in being able to provide and improve the functionalities of the Site offered to you. If you are located in the European Union, we also rely on your consent to use cookies.
What are these tools and how do we use them?
Like many companies, we may use cookies on the Site. Cookies are pieces of information shared between your web browser and the Site. Cookies enable us to offer a faster and easier user experience. A cookie cannot read data off your computer’s hard drive.
Different kinds of cookies have different functions:
The Site does use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help YouAppi analyze how users use the Site. The information generated by the cookie about your use of the Site (including your IP address) is transmitted to and stored by Google on servers in the United States. Google uses this information for the purpose of evaluating your Site use, compiling reports on Site activity, and providing other services relating to Site activity and internet usage for YouAppi and its affiliates. Google may also transfer this information to third parties when required by law or when third parties process information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. Please note, however, that if you do this you may not be able to use the full functionality of this Site. By using this Site, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
For information on all of these categories of cookies and for more information generally on cookies, please refer to aboutcookies.org.
We use cookies for the following purposes:
Where strictly necessary
We use cookies to enable you to move around this Site and use its features, such as accessing secure areas of this Site, and to improve your user experience on the Site. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
Performance and Analytics
We use cookies to collect information about how visitors use a Site, for instance which pages visitors go to most often, and if they get error messages from web pages. They also allow us to record and count the number of visitors to the Site, all of which enables us to see how visitors use the Site in order to improve the way that the Site works. We use this to improve how the Site works. We also compile statistics for analysis of the Site and our business.
Functionality
These cookies allow the Site to remember choices you make (such as your user name, language or the region you are in (learnt from your IP Address)) and provide enhanced features. For instance, a Site may be able to remember your log in details, so that you do not have to repeatedly sign in to your account when using a particular device to access the Site. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customize. They may also be used to provide services you have requested such as viewing a video or commenting on an article.
Please consult your web browser’s ‘Help’ documentation or visit www.aboutcookies.org for more information about how to turn cookies on and off for your browser.
The Site may also use web beacons (including web beacons supplied or provided by third parties) alone or in conjunction with cookies to compile information about users’ usage of the Site and interaction with e-mails from YouAppi. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Site tied to the web beacon, and a description of a Site tied to the web beacon. We use web beacons to operate and improve the Sites and e-mail communications. We may use information from web beacons in combination with other anonymous data we have about our clients to provide you with information about YouAppi and our services. We will conduct this review on an anonymous basis.
We will retain the tracking information described above for 9 months.
(III) Information when you use the Services.
As stated above, when you use the Services as a demand partner or supply partner, YouAppi collects Personal Information about your end users in order to provide you with the services. The following end user Personal Information that we collect is:
We may also collect other non-Personal Information in providing the Services including:
In collecting this information and providing you with the Services, YouAppi acts a processor on your behalf. Please note that you must ensure that our processing activities described below are consistent with the lawful basis of your own processing of Personal Information.
We will retain the Personal Information described above for the life of an active campaign and for six (6) months thereafter, or until you instruct us otherwise to delete such information, noting that we will continue to retain and use your Personal Information for longer periods only to the extent required by applicable law or auditing requirements.
(IV) Third Party Information you provide
When you supply us with information containing third-party Personal Information (names, addresses, or other information relating to living individuals) excluding Personal Information of end users provided in connection with your use of the Services, we will hold and use that Personal Information to perform services for you on the understanding that the individuals to whom the Personal Information relates have been informed of the reason for obtaining the Personal Information, the fact that it may be disclosed to third parties such as YouAppi, and have consented to such disclosure and use.
We will retain the Personal Information described above for the period in which we have an active business relationship with you or until you ask us to delete such data, noting that we may receive consent directly from the data subject of such Personal information directly, in which case the retention period and use shall be governed by our relationship with such data subject.
(V) Legal Purposes for collecting, using and disclosing Personal Information.
In addition to the above, we use Personal Information for meeting legal, security and regulatory requirements, to recover and make payments from you (including in cases of payment disputes), and to protect against suspicious or other illegal activities.
We will retain this Personal Information for the amount of time as required by law to fulfill the foregoing purposes. This may include to ensure we have an accurate record of your dealings in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings.
YouAppi will collect, use, or disclose Personal Information that is necessary for the purposes described above or as permitted by law. If we require Personal Information for any other purpose, you will be notified of the new purpose and will only be used and processed subject to your consent (where appropriate).
We do not disclose any Personal Information about you to third parties except as stated in this Privacy Policy, as permitted by law, or authorized by you. Third parties to whom we disclose information are required by law and contractual undertakings to keep your Personal Information confidential and secure in compliance with all applicable laws.
Third parties to whom we disclose Personal Information include:
YouAppi is located and maintains servers and other storage facilities in the United States (and in Japan for support of the Services provided in Japan). As a consequence of your use of the Site or the Services, Personal Information may be used or stored in the United States. By using the Site or the Services, you hereby affirmatively consent to the processing of Personal Information in a country which may not have the same level of privacy protection as your country of residence or of your end users. Should you withdraw this consent (opting out), you agree that you will not use or visit the Site or use the Services subsequent to your withdrawal of such consent. The way to withdraw your consent (opting out) is described below under the heading “Consent and user opt out”.
YouAppi will take appropriate steps to ensure that transfers of Personal Information are in accordance with applicable laws and carefully managed to protect your privacy rights and interests. To this end:
Subject to applicable laws, you have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your Personal Information when this is transferred as mentioned above. See “Your Rights” section below for more details.
Your knowledge of and consent to YouAppi’s collection, use and disclosure of your Personal Information is important. We rely on the following actions by you as indications of your consent to our existing Personal Information practices:
Where YouAppi relies on consent for the fair and lawful processing of Personal Information, the opportunity to consent will be provided when the Personal Information in question is collected. Your consent may be given through your authorized representative such as a legal guardian, agent or holder of a power of attorney.
Subject to certain legal or contractual restrictions and reasonable notice, you may withdraw this consent (opting out) at any time. YouAppi will inform you of the consequences of withdrawing your consent. In some cases, refusing to provide certain Personal Information or withdrawing consent (opting out) for YouAppi to collect, use or disclose your Personal Information could mean that we cannot provide the requested services or information for you.
If you wish to withdraw your consent (which may limit or terminate the products and services that YouAppi provides to you), simply tell us that you would like to withdraw your consent (opting out) through writing or emailing us at:
YouAppi Inc.
Attn: Customer Care
2 Embarcadero Center, Suite 2310
San Francisco, CA 94111
privacyprotection@YouAppi.com
We ask that you be specific as to whether you would like to withdraw your consent to the processing of your Personal Information or just some.
However, please note that there are a number of instances where YouAppi does not require your consent to engage in the processing or disclosure of Personal Information. YouAppi may not require your consent for the processing or transfer of Personal Information for the those purposes which have a statutory basis, such as:
YouAppi does not provide online access to its customers to view or amend Personal Information in its database, however, you have the right to ask YouAppi to amend any Personal Information it holds about you if it is inaccurate or misleading. We also note that our knowing about changes to some of your Personal Information (e.g. email address) may be key to effectively communicating with you at your request so we encourage you keep us informed of changes to your Personal Information. To update your details, please contact us by email atprivacyprotection@YouAppi.com or at the following address:
YouAppi Inc.
Attn: Customer Care
2 Embarcadero Center, Suite 2310
San Francisco, CA 94111
The following rights (which may be subject to certain exemptions or derogations), shall apply in addition to the above to EU users of the Site or the Services:
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request.
In the event that your request, for example, would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with your request in a different way than initially requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
You can opt out of having your information being used by YouAppi for performance-based advertising by accessing your mobile device settings and following the instructions here.
Please note that if you limit ad tracking or choose to opt out, you will still see advertisements, but YouAppi will no longer be able to use any personal information to serve you with more relevant ads.
In addition, the advertising identifier (along with any information collected about that identifier) that was previously assigned to you will also be disassociated. This means that if at a later stage, you decide to opt back in, we will not be able to use any of your past information and you will, for all practical purposes, be a new user to our system.
We have implemented and will maintain appropriate technical and organizational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. Note that, although we take measures to secure the information we collect and reduce the risk of unwanted disclosure, we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. Nevertheless, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. As the security of information depends in part on the security of the computer or device you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
As stated above, we may use your Personal Information to let you know about our products and services that we believe will be of interest to you. We may contact you by email, or telephone or through other communication channels. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you. To protect privacy rights and to ensure you have control over how we manage marketing with you:
California Civil Code Section 1798.83 requires any operator of a website to permit its California-resident customers to request and obtain from the operator a list of what Personal Information the operator disclosed to third parties for direct marketing purposes, for the preceding calendar year; and the addresses and names of such third parties. YouAppi does not share any Personal Information collected from the Site with third parties for their direct marketing purposes.
Do Not Track is a privacy preference that can be configured in certain web browsers (the “DNT Feature”); the DNT Feature, when enabled on a web browser, signals the websites you visit that you do not want certain information about your visit collected. YouAppi does not currently respond or recognize DNT Feature signals.
The Site or the Service may include links to other websites whose privacy policies we do not control. Once you leave our servers (you can tell where you are by checking the URL in the location bar on your web browser), use of any Personal Information you provide is governed by the privacy policy of the operator of the website you are visiting. That policy may differ from ours. If you can’t find the privacy policy of any of these websites via a link from the website’s homepage, you should contact the website directly for more information.
If you have any questions, concerns or complaints regarding our compliance with this Privacy Policy, or if you wish to exercise your rights, we encourage you to first contact us at privacyprotection@YouAppi.com. You can also contact us at the following address:
YouAppi Inc.
Attn: Customer Care
2 Embarcadero Center, Suite 2310
San Francisco, CA 94111
We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honor your wishes to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.
YouAppi will provide you with 30 days advance notice of any material change to your rights under this Privacy Policy. YouAppi will post a notice of the change on the Site in a clear and conspicuous manner for the 30-day notice period. YouAppi will also communicate the change via email or postal mail. Please note that your continued use of the Site after this 30-day period or after the Effective Date above indicates your agreement to the Privacy Policy as amended.
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