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Appreciate Privacy Policy

This Privacy Policy describes how we – Triapodi Ltd. (“Appreciate”, “we”, “our” or “us”) – collect, store, use and disclose personal data regarding individuals (“you”) who are:

i. “Visitors” that visit or otherwise interact with our company website or any other website, webpage, email, text message (SMS), notification or online ad under our control (“Sites”);
ii. “Customers” who use the Appreciate® AppOffers Demand Side Platform (“Platform”, and together with the Sites – our “Services”) to deliver their ads to End Users;
iii. “Prospects” who might be interested in engaging with us; or
iv. “End Users” or visitors of online websites and mobile applications, whose publishers use real time ad exchanges (such publishers and ad exchanges – our “Partners”) for displaying ads to their audiences, and to whom such ads are served by our Customers via our Platform and those Partners.

Specifically, this Privacy Policy describes our practices regarding:

Privacy is important to us, and we are strongly committed to transparency and fairness in our data processing activities. Please read this Privacy Policy carefully and make sure that you fully understand and agree to our practices. Remember: you are not legally required to provide us with any personal data, and may do so (or avoid doing so) at your own free will.

If you do not wish to provide us with such Personal Data, or to have it processed by us or any of our Customers or service providers, please simply do not use our Services or engage with any of the ads displayed via our Platform. You may also choose to request to delete or opt-out of certain processing activities (see Section ‎8), but please keep in mind that limiting our processing may also result in us not being able to provide you with the full range of our Services or with the best user experience when using our Services or encountering our Customers’ ads.

Triapodi Ltd. is an NAI member and adheres to the 2020 NAI Code of Conduct. If you have any question regarding this Privacy Policy, please contact us at [email protected].

1. Data Collection

We collect various types of personal data regarding our Visitors, Customers and Prospects. Such data is typically collected and generated through your interaction with us or with our Services, through automatic means, directly from you, or from other third parties.

In addition, we receive and collect personal data regarding End Users, as our systems track and monitor ad-related and engagement data related to online and mobile ads delivered by our Customers via our Platform; and as provided by our Partners involved in the process of delivering such ads to their End Users.

Specifically, we collect the following categories of data (which, to the extent it relates to an identified or identifiable individual, will be deemed as “Personal Data”):

Data automatically collected or generated: When you visit, interact with or use our Services, or otherwise visit or interact with our Partners or Customers, we may collect or generate certain technical data about you. We collect or generate such data either independently or with the help of third-party services (as detailed in Section 4 below), including through the use of “cookies” on our Sites and other tracking technologies (as further detailed in Section 5 below).

Such data mainly consists of connectivity, technical and aggregated usage data, such as IP addresses, unique advertising IDs (e.g. IDFA; you may reset such ID by following the instructions below), non-identifying data regarding a device (such as type, screen resolution), operating system, app version, mobile carrier, in-app events and various apps usage statistics, browser version, locale and language settings used, visit history, search keywords, activities and actions on the website, coarse End User location (such as city, country, ZIP code), latitude and longitude, date and time stamp, types of ads viewed and click data, the cookies installed on such device, and the activity (clicks and other interactions) of Visitors, Customers, Prospects and End Users in connection with our Services or our Customers’ ads.

Data received from our Customers and Prospects: Customers and Prospects may provide us with Personal Data such as their first and last name, address, phone number and business email as well as any other data they choose to provide when contacting or communicating with us. They may provide us additional data such as their billing details, business needs and preferences. To the extent that such data concerns a non-human entity (e.g. the bank account of a company or business), we will not regard it as “Personal Data” and this Privacy Policy shall not apply to it.

Customers and Prospects may also provide us with Personal Data concerning their colleagues or employees, in order to register them to our Services or so we could contact them directly. Such data usually refers to names, business emails and phone numbers, however additional data may be provided at the Customer’s discretion.

Data received from third parties: we may receive your Personal Data from other sources. For example, if you participate in an event or webinar that we sponsor or participate in, we may receive your Personal Data from the event organizers. We may also receive your contact and professional details (e.g., your name, company, position, contact details and professional experience, preferences and interests) from our business partners or service providers, and through the use of tools and channels commonly used for connecting between companies and individuals in order to explore potential business and employment opportunities, such as LinkedIn.

End User Data received from Partners and Customers: We receive Personal Data regarding End Users from our Partners and Customers. Such data mainly consists of the End User’s engagement with our Customers’ ads; IP address, Advertising ID (IFA), user agent, device type and model, carrier, coarse location (such as city, country, and ZIP code) or latitude and longitude coordinates, which will be collected solely for serving ads to End Users without storing such data (“End User Data”).

2. Data Uses

We use Personal Data as necessary for the performance of our Services; to comply with applicable law; to support our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, optimizing our own marketing and advertising activities, customer service and support operations, and protecting and securing the data subjects, ourselves and our Services.

If you reside or are using the Services, or engage with any ads displayed to you via our Services, (i) in a territory governed by privacy laws which determine that “consent” is the only legal basis for the processing of personal data (in general, or specifically with respect to the types of Personal Data you choose to share via the Services); or (ii) in the EEA and the processing of your Personal Data by us requires us to obtain your “consent” under applicable law (e.g. ‘special categories’ under the GDPR), your acceptance of our Terms of Use and of this Privacy Policy will be deemed as your consent to the processing of your Personal Data for all purposes detailed in this Policy. If you wish to revoke such consent, please contact us at [email protected].

Specifically, we use Personal Data for the following purposes:

  • To facilitate, operate, and provide our Services;
  • To authenticate and verify the identity of our Customers;
  • To provide Visitors, Customers and End Users with assistance and support;
  • To manage and deliver bid responses and advertisements more effectively, including contextual, behavioral and interests-based advertising based on End User activity, preferences or other data available to us or to our Partners, including for retargeting purposes;
  • To create audience related insights for optimizing ad performance;
  • To further develop, customize and improve the Services, based on common or personal preferences, experiences and difficulties;
  • To contact our Customers, Developers and Prospects with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them (as further described in Section ‎6 below);
  • To facilitate, sponsor and offer certain events, contests and promotions;
  • To support and enhance our data security and content compliance measures, including for the purposes of preventing and mitigating the risks of fraud, abuse, error or any illegal or prohibited activity;
  • To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services; and
  • To comply with any applicable laws and regulations.

In relation to End User Data we will use Personal Data for the following purposes:

  • To gain a better understanding on how End Users typically use and interact with ads delivered through the use of our Services;
  • To Improve the End User experience; and
  • To optimize the overall performance of our Services.

If you are an End User and would like to opt-out of the data collection done by our Customers via our Services, in order to provide you with interest based ads, please email us at [email protected] or follow this link: http://appreciate.mobi/appoffers-opt-out.

Please note that we may still retain certain Personal Data after you Opt-Out, in order to ensure that your request is properly handled and maintained, and for evidentiary purposes.

3. Data Location & Retention

Data Location: Your Personal Data may be processed and stored by our authorized affiliates and service providers in the United States of America, Europe, APAC, Israel, and other jurisdictions as necessary for the proper delivery of our Services, or as may be required by law.

Appreciate is headquartered in Israel, a jurisdiction which is considered by the European Commission to be offering an adequate level of protection for the Personal Data of EU Member State residents.

While privacy laws may vary between jurisdictions, Appreciate and its affiliates and Service Providers are each committed to protect Personal Data in accordance with this Privacy Policy and customary industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.

Data Retention: We retain Personal Data of Visitors, Prospects and Customers for as long as reasonably necessary in order to maintain and expand our relationship and to provide them with our Services. We also retain their data as we deem necessary to comply with our legal and contractual obligations, and to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), in accordance with our data retention policy.

We retain and use Personal Data of End Users up to 90 days following its last collection or receipt, to ensure the proper performance of our Services; to allow our Customers to properly manage and analyze their ad campaigns via our Services; and as necessary for continuously optimizing the display and performance of our Customers’ ads, and to gain further insights based on the aggregation of data available to us.

In some cases we might retain certain Personal Data for a longer period, as reasonably necessary to comply with an Opt-Out request or with any applicable laws, or if we believe in good faith that the Data might be necessary in the future for dispute resolution purposes.

We may also use non-personal or aggregated information, including such that was derived from Personal Data but anonymized or pseudonymized to remove its personally identifying characteristics. Such aggregated data may be kept indefinitely.

Please note that except as required by applicable law, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete or anonymize it for any reason and at any time, with or without notice to you.

If you have any questions about our data retention policy, please contact us by email at [email protected].

4. Data Sharing

Legal Compliance: We may disclose or allow government and law enforcement officials access to your Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect the security or integrity of our products and Services.

Service Providers: We may engage selected third-party companies and individuals to perform services complementary to our own (e.g. hosting services, data analytics services, marketing and advertising services, data and cyber security services, payment processing services, email distribution and monitoring services, and our business, legal, compliance and financial advisors (collectively, “Service Providers“). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes.

Sharing End User Personal Data with or on behalf of our Customers: We may share the Personal Data of End Users in accordance with the reasonable instructions of our Customers, each acting as the “data controller” of such data, as we act as their “data processor” and process such End User Data on their behalf. For example, based on a Customer’s instructions, we may share their End User Data with a service provider also processing such Personal Data on such Customer’s behalf.

Protecting Rights and Safety: We may share your Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of Appreciate, any of our Customers or data subjects, or any members of the general public.

Appreciate Subsidiaries and Affiliated Companies; Change of Ownership or Control: We may share Personal Data internally within our group for the purposes described in this Privacy Policy. In addition, should Appreciate or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of any or all of its assets, your Personal Data may be shared with the parties involved in such event. If we believe that such event might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via email or prominent notice on our Services.

Further Sharing of Personal Data: For the avoidance of doubt, Appreciate may share your Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.

5. Cookies and Tracking Technologies

Our Sites and some of our Service Providers utilize “cookies”, anonymous identifiers and other tracking technologies which help us provide, secure and improve our Sites, personalize our Visitors’ experience and monitor the performance of our own marketing activities and campaigns.

A “cookie” is a small text file that is used, for example, to collect data about activity on our Sites. Some cookies and other technologies serve to recall Personal Data, such as your language preference.

While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser, most browsers allow you to control cookies, including whether or not to accept them and to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

We use Google Analytics to collect information about the use of our Services. Google Analytics collects information such as how often users visit the Services, which pages they visit when they do so, and which other sites they used prior to coming to our Services. We do not merge the information collected through the use of Google Analytics with personally identifiable data. Google’s ability to use and share information collected by Google Analytics about your visits to, and use of the Services is restricted by the Google Analytics Terms of Service. You can learn more about how Google collects and processes data specifically in connection with Google Analytics here. Further information about your option to opt-out of these analytics services is available here.

If you wish to prevent the use of your mobile device’s advertising ID (e.g. for interest-based advertising), you may change your device settings to reset such advertising ID or to opt-out of such advertising (typically, this is available under the “Privacy” or “Ads” section in your device settings). You may also change your browser settings to reset or block cookies (typically, this is available under the “Settings” or “Help” section in your browser menu).

If you are an End User who lives in the USA, Canada or Europe, you can also opt-out from the collection of your data by our Partners and Customers who participate in the Digital Advertising Alliance, by visiting www.aboutads.info/choices (for US users), www.youradchoices.ca/choices (for Canadian users) or www.youronlinechoices.com (for European users).

Please note that if you reset your advertising ID or opt-out of interest-based advertising, you may still see advertisements served by Appreciate, or on any other channels, but those ads will not be targeted based on the abovementioned identifiers. For example, such ads may be instead based on context, such as your progress and actions in a certain app, or your language preference. Please note that such actions may result in less relevant ads.

6. Communications

Service Communications: We may contact you with notices and communications regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, service maintenance, etc. We may also send you notifications, messages and other updates. Typically, you will not be able to opt-out of receiving such service communications while using our Services, as they are integral to such use.

Promotional Communications: We may also send you notifications about new features, offerings, events and special opportunities or any other information we think you may find valuable. We may provide such notices through any of the contact means available to us (e.g. phone or email), through the Services, or through our marketing campaigns on any other sites or platforms.

If you do not wish to receive such promotional communications, you may notify Appreciate at any time by sending an email to [email protected] or by following the “unsubscribe”, “stop”, “opt-out” or “change email preferences” instructions contained in the promotional communications you receive.

7. Data Security

In order to protect your Personal Data held with us and our Service Providers, we are using industry-standard physical, procedural and electronic security measures, including encryption as appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any Service Providers as described in Section 4 above.

8. Data Subject Rights

If you wish to exercise your rights under any applicable law, including the EU General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA), such as the right to request access to, and rectification or erasure of your Personal Data held with Appreciate, or to restrict or object to such Personal Data’s processing, or to port such Personal Data, or the right to equal services and prices (each to the extent available to you under the laws which apply to you) – please contact us by email at [email protected] or follow this link: http://appreciate.mobi/appoffers-opt-out. You can also contact us if you wish to opt-out of the sale of your Personal Data.

Please note that once you contact us by email, we may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 3 above.

If you are an End User and you wish to make any requests regarding Personal Data we process on behalf of our Customers and/or Partners, please contact them directly (as they are the “data controller” of such data, and ultimately control and are responsible for handling your request – see Section 10 below).

9. Children’s Privacy

Our Services are not designed to attract children under the age of 16. We do not knowingly collect Personal Data from children and do not wish to do so.

If we learn that we collected data relating to a person under the age of 16, we will make all efforts to promptly delete any Personal Data stored with us with regard to such child. If you believe that we might have any such data, please contact us by email at [email protected].

10. Data Controller/Processor

Certain data protection laws and regulations, such as the GDPR or the CCPA, typically distinguish between two main roles for parties processing Personal Data: the “data controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “data processor” (or under the CCPA “service provider”), who processes the data on behalf of the data controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.

Appreciate is the “data controller” of its Visitors’, Prospects’ and Customers’ Personal Data, and with respect to which, assumes the responsibilities of data controller (solely to the extent applicable under law), as set forth in this Privacy Policy.

If a Customer or Partner provides us with any End User Data, or Appreciate otherwise obtains any such Personal Data and processes it on the Customer’s behalf, such Customer shall be deemed the “data controller” of this data, and Appreciate will be processing such End User Data as the Customer’s “data processor”. This will be done in accordance with the Customer’s reasonable instructions, subject to our Terms of Service and other commercial agreements. The Customer will be solely responsible for meeting any legal requirements applicable to data controllers of such data (such as establishing a legal basis for processing and responding to data subject requests concerning the data they control). The same will apply in regards to Personal Data received from our Partners (unless such data will be used for Appreciate own needs, in which case Appreciate will assume the role of “data controller”)

If Appreciate collects and processes any End User Data on its own behalf, for example so it could analyze such data and obtain insights concerning user types or groups, Appreciate shall be deemed as the “data controller” of such Personal Data.

If you would like to make any requests or queries regarding Personal Data we process on our Customers’ or Partners’ behalf, please contact them directly. Should we receive such requests directly, we may refer them to our Customer and/or Partner, as applicable.

11. Additional Notices

Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the date it is so published. We will provide an advance notice if we believe any substantial changes are involved via any of the communication means available to us or via the Services. After such notice period, all amendments shall be deemed accepted by you.

Third-Party Websites, Links, Ads and Content: Our Services and ads served via our Platform may provide links to certain third-party websites or referrals to certain third-parties’ products or services. If you choose to visit a third-party’s website or use its products or services, please be aware that Appreciate does not endorse and cannot ensure that you will be satisfied with any such products or services, and that the third-party’s privacy policy will govern your activities and any data they collect about you and/or you disclose while interacting with such third-party.

Please also note that Appreciate is connected directly to Google’s Authorised Buyers platform, which allows us to bid and serve ads on Google’s Authorised Buyers Inventory in real time. To learn more about how Google collects and processes data, see Google Privacy Policy.

This Privacy Policy does not apply to websites, ads, applications or services other than our Services, even if our Services are embedded/linked to therein; or to websites, ads, apps or services that are not expressly and officially provided by Appreciate. Please be aware that opting out of our Services or ads delivered via our Services does not necessarily imply that you are opting out of any publisher’s website, ad hosting app/website or any other third-party’s website and/or services. Appreciate is not responsible for any operation or collection of data by any publishers’ or advertisers’ websites, ad hosting apps/websites, products, applications or services, or any other third-party web sites, services, products and/or apps. We strongly encourage you to make whatever investigation you feel necessary or appropriate before proceeding with any online or offline transaction or engagement with any third parties.

Questions, Concerns or Complaints: If you have any comments or questions about this Privacy Policy or if you have any concerns regarding your Personal Data, please contact us by email at [email protected]. Appreciate’s appointed Data Protection Officer may be reached by email at [email protected].

EU and UK Representative: Dr. Andreas Mätzler of Prighter has been designated as Appreciate’s representative in the European Union and the United Kingdom for data protection matters pursuant to Article 27 of the GDPR and the UK-GDPR. Inquiries regarding our EU & UK privacy practices may be sent by e-mail to [email protected] or via mail.

If you want to contact us via our representative Prighter or make use of your data subject rights, please visit: https://prighter.com/q/18159319, or:

EU inquiries may be sent to:

Prighter (Re: Triapodi / Appreciate)

Schellinggasse 3/10

Vienna 1010

Austria

UK inquiries may be sent to:

Prighter (Re: Triapodi / Appreciate)

Kemp House 160 City Road

EC1V 2NX, London

United Kingdom

If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the EU or in the UK as applicable to you.

Effective Date: November 8, 2021