1. INTRODUCTION
Appxem operates a marketing platform solution that offers advertising and monetization services/products to marketers and supply partners through digital media, websites, surveys, owned or operated application(s)/widgets, exchange(s) for demand/supply, marketing automation solutions, and other services, including fraud detection, reporting, audiences, attribution, analytics, modelling, segments, and measurement ("Marketing Platform").
2. SCOPE OF THIS PRIVACY POLICY
2.1 APPLICABILITY
This privacy statement describes how Appxem collects, uses, and disseminates information from users of its websites, services, and other platforms that make up its marketing platform (collectively, the "Marketing Platform Services"). Unless otherwise noted, Appxem is the controller of the personal data we process. As for a Network Advertising Initiative (NAI), abides by the NAI Code of Conduct.2.2 NON-APPLICABILITY
Appxem may provide consumers with smart devices through independent mobile applications, web content services, lock-screen platforms, social entertainment platform(s), widgets, and/or other software features that may be preloaded on the devices, downloadable, hosted on the web, or made available through other digital media ("Consumer Offering"). The data that is collected by or processed by each of the aforementioned services is not covered by this privacy policy. The relevant privacy policy should be accessible to you through such services if you are a consumer of any such consumer offering. Refer to each Consumer Offering's individual privacy policies for a description of its data gathering and data use procedures. The terms of this policy would apply to the data processing methods for such Marketing Platform Services to the extent that the aforementioned Consumer Offering encourages any interest-based advertising using the Marketing Platform Services.The term "Services" refers to both consumer offerings and marketing platform services.
3. APPXEM MARKETING PLATFORM SERVICES
Through a variety of advertising channels, including exchanges, networks, and off-networks, Appxem collaborates with third-party site/app publishers and app developers to deliver ads on their digital properties on behalf of its demand-side advertising partners. Ads may also be served by Appxem on consumer offerings. Campaign planning, measurement (such as determining whether an advertising was viewed, its timestamp, etc.), and attribution of advertisements are additional services provided by Appxem. Appxem offers marketing platform services such as ad campaign optimization, data analytics and enrichment, segmentation, user acquisition, retention, and remarketing or retargeting through various digital advertising platforms. Appxem collects data into its Marketing Platform from a variety of sources, including end user information gathered by our systems, applications/offerings, partners, data/cookie vendors, or customers ("Sources"). These sources may include third party apps, sites, and services that you use. To learn how the apps, sites, and services you use gather, use, and share data from your interactions with them, please see the privacy policies of such apps, sites, and services. These third-party apps, websites, and services' collection and use of data is not within the control of appxem.4. WHAT PERSONAL INFORMATION DO WE COLLECT?
We could gather data about your device and how you interacted with an advertisement when you saw one that was distributed by Appxem on a website, app, or other digital medium. With the use of this information, we are able to better present you with adverts and provide our services, such as identifying your device when you visit other websites and use third-party apps that we have partnered with. If you choose to participate in one of our surveys or opinion-based applications, Appxem may additionally gather information about you at that time. Among the data we might gather are: (a) Device identifiers. Device identifiers are alphanumeric strings that are unique to your device. These include:- iOS devices’ Identifier for Advertising (IDFA) and iOS Identifier for Vendors (IDFV)
- Google Advertising ID (GAID), or Android ID for Android devices
- Identifier for Advertising on OTT and CTV platforms
- International mobile equipment identity (IMEI), in certain jurisdiction as permitted by applicable law
- Cookie IDs
- Geo-location or precise location of your device if you have given the app or site permission to collect your location information
- Location information we infer based on data collected through a WiFi identifier that your device is connected to, in accordance with applicable law and provided location access is permitted
- Location information we infer from your device’s IP address, provided that we will not infer location from an IP address to a more precise than city-level of accuracy unless you have given the app or site permission to collect your location information
- Mobile carrier
- Network provider or ISP
- Network type (e.g., WiFi or cellular)
- IP address
- IDs of WiFi access points to which your device is connected
- Date and time of connection
- App or site name or version
- App identifier
- SDK version
- API key identifier
- Device type (e.g., make and model)
- Device startup time and update time
- Device name
- Screen size
- Memory and hard drive capacity
- Operating system and version (e.g., iOS 14, Android, Windows, Blackberry)
- Mobile browser used (e.g., Chrome, Safari, Firefox)
- Language settings (including country code) and time zone
- App usage
- The content type of the ad (the advertiser and category, e.g. games, finance, entertainment, news)
- The ad type (e.g. whether the ad is a text, image, video or other format based)
- Where the ad is being served (e.g. the site, digital media or app on which the ad appears)
- Whether you viewed, clicked or otherwise interacted with the ad
- Age
- Name
- Email address
- Phone number
- Gender
- Occupation and income range
- Family size and other demographic information
- Preference for brands, modes of travel, and other consumer choices.
How Google uses data when you use our partners' sites or apps
We do not collect any sensitive data such as racial or ethnic origin, political opinions, religious or philosophical beliefs, genetic data, biometric data, data5. HOW DO WE USE YOUR PERSONAL INFORMATION?
We use the information that we collect about your device to:- Display advertisements on your device, which may include interest-based advertising customized to your interests, preferences, locations
- For remarketing or retargeting i.e. to display relevant ads if you have previously visited/accessed/downloaded a site or mobile application that we partner with
- For bidding to serve advertisements and to determine which ads are most effective
- Analyze and provide our demand partners or advertisers reports on the effectiveness of advertisements and campaigns, including across different types of devices based on our determination of devices that are related to the same person. We, or third parties whom we engage to provide this service, may use cross-device data to provide interest-based advertising services and to deliver tailored ads to users across multiple mobile devices including over the top applications and smart televisions
- Avoid showing you the same ads too many times
- Build custom audience segments to enable our customers and partners better target their advertisements and offers
- Improve our Services and assist our customers and partners in improving their products and services
- Detect, deter and prevent fraud, fraudulent traffic or to protect the security of our systems
- We may process your survey responses and share the response data with the brands who are our customers/marketers
6. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
Appxem may share the information we collect or receive about you as described in this Policy as follows:- Publishers and Supply Partners. We may share your information with publishers (the app or site publishers) to help them understand how users interact with their apps and sites and advertisements on their apps and sites
- Demand Partners and Advertisers. We may share your information with demand partners, brands and advertisers who use our Marketing Platform, to allow them to understand the performance of their campaigns; and to help them better target their campaigns, products or offerings
- Marketing Partners. We may share your information with data partners who help us with better understanding your preferences by providing data enrichment, analytics and identification services and measurement companies who help us with attribution and tracking of advertisements distributed through us (“Marketing Partners”)
- Service Providers. We may share personal information we collect about you with our third-party service providers. The categories of service providers to whom we entrust personal information include: IT and related services; fraud detection, information and services; payment processors; customer service providers; and vendors to support the provision of the Services
- Group. We may share personal information with the Group so that the Services of Appxem and/or the Group may be improved and otherwise to serve you and/or our customers better with all our offerings including effective content management “Group” as used in this policy, means, with respect to Appxem, its affiliates and group entities listed here.
- Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity
- Disclosures in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract<,/li>
- International Data Transfers. Where applicable, we will protect information through other legally valid methods, including international data transfer agreements. You agree that all information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. Further details can be provided upon request.
7. HOW DO WE KEEP PERSONAL INFORMATION SECURE?
Appxem uses reasonable technical and organizational measures to protect the information it collects about you in compliance with its legal and privacy requirements and contractual obligations. We also seek appropriate contractual protection from our partners regarding their collection, use or treatment of user data. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure. By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.8. HOW LONG DO WE KEEP YOUR INFORMATION?
Appxem retains information collected in the context of our Marketing Platform for a period of up to thirteen (13) months, unless otherwise required by law or applicable contract. Appxem may retain the information it obtains about you as per the instructions of its customers or partners who provide such information or as required to fulfil our contractual obligations. In case any information is provided by you in participation of a survey or opinion-based application by Appxem, we will only retain your personal data for as long as necessary to fulfil the purposes we collected it for. After the applicable retention period, Appxem will only retain and may only use your data: (i) in an aggregated or anonymized format; (ii) to comply with its legal obligations; and (iii) to resolve disputes and enforce agreements. Please note that the use cases stated in this provision will apply as an exception to your data subject or consumer rights related requests.9. OPTING OUT OF INTEREST BASED ADS
Opting out of interest-based advertising: If you prefer not to receive interest-based advertising from Appxem, you can opt out at any time by going to the Appxem Opt Out page and submitting your device ID or any other listed identifier. If you opt-out of interest-based advertising, you will still receive generic ads from Appxem. To opt-out of our cross-device ad targeting, you must opt-out on every device browser and device using the appropriate opt-out methods. Opting out of surveys: Each survey that you participate in will provide opt-out instructions, including an option to skip questions, which if elected will ensure that we do not include your device for that survey. Please note that if you opt-out of a survey you may still receive other survey requests. If we reach out to you through marketing communication modes such as emails, you will have the option to unsubscribe from such marketing communications through links provided in such emails. Opting out of Connected TV: If you opt-out of interest-based ads on your connected TV device, your advertising ID will not be used to build profiles or target you with interest-based ads and it is likely that you will get irrelevant ads which are not tailored to your interest. To disable interest-based ads, please use the Opt-Out on your Connected TV device as shown below. On your device, visit Operating System (OS) Privacy Settings. Select Limit Ad Tracking (for iOS/tvOS devices), Opt-out of Interest-Based Ads (for Android devices), Limit Ad Tracking (for Roku devices), or similar setting offered by your OS. Please go through your device manufacturer’s privacy policy for more information. You may also opt out of interest-based advertising via NAI. Please visit Mobile Choices | NAI: Network Advertising Initiative for opting out of interest-based ad on mobile devices and Internet Connected TV Choices | NAI: Network Advertising Initiative on TV.10. PRIVACY RIGHTS
Appxem provides consumers with data subject or consumer rights as and when and to the extent required under such applicable laws. General Data Protection Regulation (GDPR): 1.1 The terms "Controller," "Data Subject," "Personal Data," "Processor," "Processes/Processing," and Sub-Processor shall each, for the purposes of the Data Protection Regulation, have the same meanings as set forth in the General Data Protection Regulation ("GDPR") and/or any other applicable Data Protection Legislation, and shall each be interpreted in accordance with the GDPR and/or the applicable Data Protection Legislation.1.2. Data protection laws include I the General Data Protection Regulation ("GDPR") ((EU) 2016/679) and any national implementing laws, regulations, and secondary legislation, as amended or updated from time to time, and (ii) any successor legislation to the GDPR or the Data Protection Act 1998 when the GDPR is no longer directly applicable in the United Kingdom.
1.3. According to GDPR or any other applicable data protection laws and regulations, a "Individual" is a natural person whose Personal Information pertains to them and who is also known as a "Data Subject" for purposes of the Data Protection Regulation.
1.4. According to EU data protection rules and regulations, "Personal Information" is defined as information on a named or identifiable individual for the purposes of the Data Protection Regulation.
1.5. In terms of the Data Protection Regulation, "Service" refers to the proprietary technology used by Appxem and/or its Affiliates to enable and optimise publishers' and advertisers' ability to sell and buy ad space inventory on specific mobile applications and mobile/desktop websites, including through programmatic auction (if applicable).
1.6. A human end-user who accesses a mobile/web application/website is referred to as a "User" for the purposes of the Data Protection Regulation.
California: The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents with the right to know what categories of personal information Appxem has collected about them and whether Appxem disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “4. WHAT INFORMATION DO WE COLLECT?” and “5. HOW DO WE USE YOUR INFORMATION?” above, respectively. The categories of third parties with whom we may share your information are listed in “6. WHO DO WE SHARE YOUR INFORMATION WITH?” above.
California residents have the right to opt out of the “sale” of their personal information. Under the CCPA, “sale” is defined broadly and includes the transfer of personal information by a business to a third party for valuable consideration (even if there is no exchange of money). Appxem may be deemed to be “selling” personal information. The categories of personal information we have “sold” and the categories of third parties we have “sold” personal information to in the preceding twelve months are listed in “6. WHO DO WE SHARE YOUR INFORMATION WITH?” above.
Residents of the State of California (in the United States) have the following additional privacy rights:
- You have a right to exercise certain consumer rights such as request to know/ disclose/ access/ delete your data, collected in the last 12 months, by writing to us at privacy@appxem.com.
- You have the right to opt out of selling of your data by clicking on the following link: Do not sell my data.
11. INTERNATIONAL TRANSFERS
Appxem may share your information with clients, customers, partners, the Group and other third parties described above who are based in countries outside of your country of residence (for example, if you are an EEA resident, we may share your information with our non-EEA clients or the Group), subject to any contractual or legal requirements. You agree that all information processed by us may be transferred, processed, and stored anywhere in the world. While some countries may not have data protection laws that are equivalent to those of the country in which you reside, we will take reasonable measures to protect your information in accordance with this Privacy Policy.12. LEAD GENERATION CAMPAIGNS
Appxem may offer form-based advertising solutions to marketers that include the collection of voluntary information from you as part of an advertisement that contains a questionnaire. Such information may consist of personal data, non-personal information or data, or both. All the information that you voluntarily provide in response to such form or questionnaire is typically forwarded directly to the relevant marketer’s servers or their landing page and in such cases will be governed by such marketer's privacy policies in place at the time of transfer. In the event any personal data is directly processed by Appxem, you acknowledge that appxem may be required to store such information for the period during which it continues to manage the applicable lead-generation campaign for its marketer on whose behalf the information is collected. This information may be temporarily stored by appxem solely for running such form-based campaigns and will be used only for the purpose of optimization of such campaigns, subject to applicable legal/privacy and contractual requirements. appxem has implemented internal safeguards to protect the temporary storage of this information and uses reasonable technical and organizational measures to protect the same. appxem has mechanisms to delete or anonymize any personal data after the said campaign is concluded or within a period thirty (30) days from the same. Pursuant to the conclusion of the applicable campaign, appxem may retain and use your Information only to the extent necessary for it to create reports for its client, comply with its legal obligations, resolve disputes and enforce agreements and no other purpose. Any non-personal information or data submitted by you may be used for improving our Services. If you have any questions about appxem lead generation campaigns, please contact us at: privacy@appxem.com. appxem will refer any enquiries or complaints to the relevant marketer responsible for the processing of data provided as part of lead generation campaigns.13. COOKIES
We use cookies and beacons to help us collect some of the information we have described above. This may be done when you interact with us or our third-party partners who enable appxem to collect data related to your interaction with their apps or sites for the purpose of serving relevant Ads to you and/or improve our services. We may also use cookies on our and our advertiser’s websites to provide website functionality and advertising to you respectively, and to save you having to provide the information you have already given us on subsequent visits to our site. For more detailed information about the technologies we use and your ability to control those cookies, please visit our cookie policy. We recommend that you review the privacy policies of the third-party apps, services or sites that you directly interact with to learn how those third parties use cookies.14. PRIVACY OF CHILDREN
appxem complies with the age-gating requirements under applicable privacy laws such as Children's Online Privacy Protection Act (COPPA) and California Consumer Privacy Act (CCPA) in the U.S., Lei Geral de Proteção de Dados Pessoais (LGPD), General law of personal data protection in Brazil and GDPR in the EEA and does not knowingly collect personal data about users of sites or apps directed to children. Please also visit our COPPA Policy.15. OTHER WEBSITES
Our website and the ads we service may contain links to other websites. You should be aware that we are not responsible for the privacy practices of such other websites as those may have different privacy policies and terms of use and are not associated with us. You agree that we cannot control these links and we shall not be responsible for any use of such websites.16. CHANGES TO THIS PRIVACY POLICY
We may amend this Privacy Policy at any time. The amended Privacy Policy will be displayed on our site. If we make any material changes, we will notify you by means of a notice on this site prior to the change becoming effective. Please check our Privacy Policy regularly to ensure you have read the latest version.17. CONTACT US
A data protection officer has been appointed by Appxem in India. Please send us an email at dpo@appxem.com if you want to exercise your rights regarding personal data or if you have any questions about this privacy statement or our privacy practices.The Privacy Policy was last updated on 07-11-2023