App Samurai, together with its affiliates (collectively referred to as “we”, “our”, “us or “AppSamurai”) is keen to keep up with Privacy standards and obligations and more importantly protect and respect privacy of your personal data. By this policy we would like to explain you how we treat your personal data when you visit our Website appsamurai.com and our practices for collecting, using, maintaining, protecting and disclosing that information.

In case of any questions or requests relating to data protection, please get in touch with us at privacy@appsamurai.com.

This policy describes the types of information we may collect from you and our practices for collecting, using, maintaining, protecting and disclosing that information. 

This policy applies to information we collect:

• when you visit the website https://appsamurai.com (“Website”)
• in email, text and other electronic communication between you and us.
• when you interact with us on any third-party websites and services, if those applications or advertising include links to this policy.
• when using our App Samurai Dashboard.
• When you take part in any feature, grant, campaign through our website 

It does not apply to information collected by:

• us offline or through any other means, including on any other website operated by App Samurai or any third party including through any application or content (including advertising) that may link to or be accessible from the Website or dashboard.

Types of Information we collect and how we collect them

Content

Personal data is all information relating to personal and objective circumstances through which a person may be personally identified. This may for example entail information such as:

• information you provide to us when you use our Website and dashboard.
• questions, queries or feedback you leave, including your email address if you send an email to us
• your IP address, and details of which version of web browser you used
• information on how you use the website, using cookies (cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie). For more explanation please see our Cookie Policy.
• information that you provide us by communicating with us through any chat window on the website or “contact us” forms and “demo scheduling” forms or subscribing to our newsletter. This includes contact details such as name, email address and similar.
• Information that you provide us for using our tracking tool as well as your records on these actions and any personal information in data that you send to us throughout our communication with you.
• If you want to work with App Samurai, you may submit your credit card information. This record is kept by third-party payment processor (Stripe Inc.).
• If you contact us for demo, customer or technical support, we may keep a record of that correspondence or conversation by receiving your consent at the beginning of any correspondence.
• Information we receive from third-party search engines such as Google relating to your search queries that brought you to our Website.
• Details of your visits to our Website including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access.

How we intend to and practically use your information

This data is necessary for the following purposes:

• Improve the website by monitoring how you use it and to recognize you when you return to our website.
• respond to any feedback you send us if you’ve asked us to
• To estimate the size of our target group and their user pattern.
• To save information about your preferences so that we may adapt our website and our services. To your individual interests.
• To provide you with a better user experience
• ensure the stability and security of our website.

• To present our Website and its contents to you.
• To provide you with information, products or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Website or any products or services we offer or provide through it and to help us understand how the Website is being used.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.
• We may also use your information to contact you about goods and services that may be of interest to you. If you do not want us to use your information in this way, you may elect to unsubscribe, and we will cease using your information in that manner.
• To evaluate your application to any of our campaigns, grants, features

Actual Information We Collect About You When You Visit Our Website

We collect several types of information from and about users who visit our Website via internet connection or through your device which you use to access our website, including certain user details. Such information includes:

• traffic data,
• geo information and locale,
• logs and communication data,
• resources on our website which you access and use,
• IP address, operating system and browser type,
• and information which is collected through cookies, web-beacons and other tracking technologies.

The information mentioned above are already anonymized data which are given us by Google Analytics. You can get more information about Google analytics privacy policy via: https://policies.google.com/privacy?hl=en-US

• Furthermore, we may collect data which you may be personally identified such as your name, postal address, email address, phone number and any other identifier with which you may be contacted online or offline (‘personal data’) insofar as you provide us with this data.

By:

• Cookies (or browser cookies). We, and businesses we work with, require for some features of our website. Cookies are small files that your browser places on your device in a designated directory. These cookies can be used to determine, for example, whether you have visited a website before. Most browsers accept cookies automatically. However, you can set your browser so that no cookies are stored or an explicit consent is required before saving a cookie. In addition, you can delete previously set cookies at any time. Please note that disabling cookies may result in restrictions when using our website. Please see our Cookie Policy for more info.
• Log files. Every time you access our Internet pages, your usage data is transmitted through the respective internet browser and stored in log files, the so-called server log files. The records stored in this case contain the following data: domain and location from which the user is accessing the website

• Additionally, we can receive information from third parties, for example business partners.

• Information that you provide by filling in forms on our Website. This includes information provided at the time of subscribing to our newsletter, subscribing to our service, or requesting further services. We may also ask you for information when you report a problem with our Website or the dashboard.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
• Details of Website searches and button clicks are also recorded.
• You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Third-party Services, Use of Cookies and Other Tracking Technologies

Third party’s services, such as Hubspot, Stripe and Google Analytics are incorporated into the website or our technologies but are governed by their respective privacy policy.

Some third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. We do not control these third parties’ tracking technologies or how they may be used. 

Accuracy of Data, Transparency, Choice and How long we keep your personal information

• We do our best to keep your data accurate and up to date, to the extent that you provide us with the information we need to do so. If your data changes (for example, if you have a new email address), then you are responsible for notifying us of those changes. Upon request, we will provide you with information about whether we hold, or process on behalf of a third party, any of your Personal Information.
• We will retain your information for as long as your account is active or as long as needed to provide you with our services. We may also retain and use your information in order to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our agreements.
• We store and retain your personal information for as long as you use the website and/or remain subscribed to our newsletter or blog. After this time how long we keep the information, we collect about you depends on the type of information as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.
• We retain Personal Information that you provide to us where we have an ongoing legitimate business need to do so (for example, as long as is required in order to contact you about your account or our other services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements). When we have no ongoing legitimate business need to process your Personal Information, we securely delete the information or anonymize it or, if this is not possible, then we will securely store your Personal Information and isolate it from any further processing until deletion is possible. We will delete this information from the servers at an earlier date if you so request.
• We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
• In any case, as long as App Samurai uses your personal information to provide the Services, we will retain the personal information about you, unless we are required by law to delete it, or if we accept your request to delete the information, pursuant to applicable laws, or if we decide to remove it at our own discretion.
• We will give an individual access to any Personal Information we hold about you at most within 30 days of any request for that information by contacting us at privacy@appsamurai.com. Unless it is prohibited by law, upon your request, we will remove any of your Personal Information from our servers. There is no charge for an individual to access or update their Personal Information.

Basically, we store your personal information:

• if you have consented to the processing at the latest until you revoke your consent,
• if we need the data to carry out a contract at most as long as the contractual relationship with you or statutory retention periods are running,
• if we use the data on the basis of a legitimate interest at most as long as your interest in deletion or anonymization does not prevail.

Disclosure of your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect, or you provide as described in this privacy policy:

• To our subsidiaries and affiliates for the sole purpose of providing our services.
• To contractors, service providers and other third parties we use to support our business.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of company assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of use and other agreements or applicable T&C signed between you and us, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our, our customers or others.

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website may then be inaccessible or not function properly.
• Opt-out. You may “opt out” of receiving marketing or promotional emails from us by following the instructions in those emails. If you opt out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations.
• If you subscribe to our newsletter, we will process your email address and data to verify your subscription. You can cancel your subscription at any time by sending a message to us or by clicking the ‘unsubscribe’ button.
• We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. 

Compliance, Your consent and How we protect Your Data

• We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. All transactions, regardless of their nature, are encrypted.
• Our servers are located in Europe, so your information may be transferred to, stored, or processed in Europe. While the data protection, privacy, and other laws of the EU might not be as comprehensive as those in your country, we take many steps to protect your privacy. By using our Website, you understand and consent to the collection, storage, processing, and transfer of your information to our facilities in the EU and those third parties with whom we share it as described in this policy.
• If you are a resident in a jurisdiction where a transfer of your personal information to another jurisdiction requires your consent, then you hereby provide us your express and unambiguous consent to such transfer or by using the website you hereby provide your express consent to such transfer (as applicable).
• Additionally, the safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
• Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
• Transfer between subsidiaries: We may transfer user and customer information to our affiliates and to third party providers for the sole purpose of providing our services.

Aggregated and Analytical Information

• We use standard analytics tools. The privacy practices of these tools are subject to their own privacy policies, and they use their own cookies to provide their service (for further information about cookies, please see our Cookie Policy).
• We use the standard analytics tools of Google Analytics, and we will use additional or other analytics tools, from time to time, to learn about how you and other users use the Service, in support of our Service-related activities and operations.
• The privacy practices of these tools are subject to their own privacy policies. See Google Analytics Privacy Policy at: Privacy Policy – Privacy & Terms – Google.
• We use anonymous, statistical, or aggregated information and will share it with our partners for legitimate business purposes. It has no effect on your privacy, because there is no reasonable way to extract data from the aggregated information that we or others can associate specifically to you. 

Your rights according to the GDPR

As the data subject, you have the right of access (Art 15 GDPR), the right to rectification (Art 16 GDPR), the right to erasure of your personal data (Art 17 GDPR), the right to restriction of processing of your personal data (Art 18 GDPR) as well as the right to data portability (Art 20 GDPR). 

You can always contact us if you want to revoke your consent to the processing of your personal information. Exercising any of these rights will not affect the lawfulness of processing based on consent before its withdrawal.

You can object to the processing of your personal data insofar as we base the processing of your personal data on the balance of interests. This is the case in particular if the processing is not necessary for the fulfilment of a contractual obligation to you, which we in each case present in the description of the functions which follow. In case of such objection, we kindly ask for an explanation of the reasons for the objection against the processing of your personal data. In the case of your justified objection, we will examine the situation and will either discontinue or adapt the data processing or point out to you our compelling legitimate reasons based on which we continue the processing your personal data. You also always have a right to lodge a complaint with a data protection supervisory authority.

You may, of course, object to the processing of your personal data for advertising and data analysis purposes at any time.

In this case, please send an email to privacy@appsamurai.com

Your California Civil and Data Protection Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal information which we share with our affiliates and/or third-parties for marketing purposes, and providing contact information for such affiliates and/or third-parties. If you are a California resident and would like a copy of this notice, please submit a written request to privacy@appsamurai.com

Starting January 1, 2020, the California Consumer Privacy Act (CCPA) provides additional privacy protections for California data subjects and users, including: a) the right to see what data we have about you, your computer or device (i.e., the right to know), b) the right to delete the data we have about you, your computer or device (i.e., the right to delete) and c) the right to opt-out of the sale of data about you, your computer or device to certain third-parties (i.e., the right to opt-out from sales of your information). We do not discriminate against you if you exercise any of the above rights. Moreover, we may not be able to honor a right if doing so would violate applicable law.

You can exercise any of these rights by submitting a request through our Privacy Request Form.

Your Rights as an Individual in EEA (European Economic Area)

We process data as a data controller (as such terms are defined in the GDPR). As a controller, we are committed to fulfilling data subjects’ (‘Users’) GDPR rights.

As an EEA resident, you may:

• Access the data that we keep about you. We may need to ask you to provide us certain credentials to make sure that you are who you claim you are. If you find that the data is not accurate, complete or updated, then you may provide us the necessary information to rectify it.
• Contact us if you want to withdraw your consent to the processing of your personal information. Exercising this right will not affect the lawfulness of processing based on consent before its withdrawal.
• Request to delete or restrict access to your personal information. We may postpone or deny your request if your personal information is in current use for providing the Services or due to other legitimate purposes, such as compliance with regulatory requirements associated with AppSamurai.

If you exercise one (or more) of the above-mentioned rights, in accordance with the provisions of applicable law, you may request to be informed that third-parties that hold your personal information, in accordance with this Policy, will act accordingly.

• You may ask to transfer your personal information in accordance with your right to data portability.
• You may object to the processing of your personal information for direct marketing purposes.
• You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affecting you.
• You have a right to submit a complaint with a data protection supervisory authority.

We do periodical assessments of our data processing and privacy practices, to make sure that we comply with this policy, to update the policy when needed, and to verify that the policy is displayed properly and accessible.

If you have any concerns about the way we process your personal information, you are welcome to contact AppSamurai’s data protection officer at privacy@appsamurai.com, or write to us at 287 Park Avenue South, Suite 700 New York, NY 10010 USA. 

If you are located in United Kingdom, you can also write us at 71-75 Uxbridge Road Ealing, London United Kingdom, W5 5SL.

We will look into your enquiry and make good-faith efforts to resolve the matter. If you remain unhappy with the response you received, you can also refer the matter to the data protection authorities in your region.

You can exercise any of these rights by submitting a request through our Privacy Request Form.

Processing of data by App Samurai

We provide mobile marketing and advertising services to mobile app developers (our “Customers”). In connection with these services, we may process certain data from the users of these mobile apps (collectively the “End User”) as further described hereafter. We process the data upon instructions from our Customers and do not have any kind of direct relationship with the End User.

Customers who have child-directed apps must choose the appropriate product settings and must not share any personal data with any third parties. 

Our SDK and APIs may process some of the following data from You as the End User:

• IP address
• Mobile identifiers 
• Installation and first opening of an app on Your mobile device
• Your interactions within an app (e.g. in-app purchases, registration)
• Information regarding which advertisements You have seen or clicked on

We use the aforementioned data for providing marketing and advertising services to our Customers, and thereby allow our customers to track their marketing performance, to match You to their campaigns and to understand how You engage with our Customer’s app. Furthermore, we enable our Customers to track Your interactions in their apps in real time in order to see how You engage over their full lifetime. The aforementioned data is therefore processed in order to analyze the performance of marketing campaigns and to provide performance reports to our Customers. We do not combine the data with any other data that would enable us to personally identify You. Any information processed by App Samurai is owned and controlled by our Customer who has implemented our technology into their mobile app. 

We do not share or disclose the user data with anyone else except with our server providers and in response to lawful requests by public authorities, including national security or law enforcement requirements. The personal data is anonymised as soon as collected and We store only such anonymized data as long as our Customers are using our technology because we need it to provide our services to our Customers, if not requested otherwise by our Customers. To this end, any analytics use of the Customers for the purposes of the Services is made on anonymized information.

Security

Safeguarding Your Information

We have procedures and security features in place to try and keep your data secure once we receive it.

We take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal information with;

• Cyber security.
• Support, customer relations, service operations.
• Fraud detection and misuse of the Service and Website.

We will not share your information with any other organizations for marketing, market research or commercial purposes, and we don’t pass on your details to other websites and online platforms.

Your accounts require e-mail address and password to log in. You must keep your username and password secure. You must prevent unauthorized access to your account and personal information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account. 

We endeavor to protect the privacy of your account and other personal information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. Any data you transmit is at your own risk.

Children Under the Age of 16

Our Website is not intended for children under 16 years of age. Under GDPR Article 8, the age of consent, i.e. when a child is required or able to give their consent for the processing of the own data, is 16. Therefore, we do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us via email at privacy@appsamurai.com or per phone at +1 415-944-1409.

Contests, Grants, Sweepstakes, Surveys and sharing your information with third parties.

We may, from time to time, offer surveys, contests, grants, sweepstakes, or other promotions on our website or through social media (collectively “Our Promotions”). Participation in our Promotions is completely voluntary and in order to participate, you may need to provide personal contact information such as your name, phone number, email address, username, and similar details and information as detailed above. We use the information you provide to administer Our Promotions. If you have explicitly permitted us to do so, we may use the information provided to communicate with you, or other people you select, about our Services.

Additionally, by participating in our promotions you give your explicit and absolute consent to share your personal information to third parties, where the sharing of your information is necessary for the fulfillment of our Promotions in line with their respective guidelines or terms and conditions.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified below. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our website and this privacy policy to check for any changes.

Please note that Our use of the data is also governed by the agreement you enter into with us in connection with our Services. In the event of any conflict between this Privacy Policy and the service agreement, the agreement shall prevail.

We commit to process personal information solely for the purposes described in this policy.

Updated on March 1, 2023