Policy summary
Personal Data processed for the following purposes and using the following services:
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Analytics
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Facebook Analytics for Apps
Personal Data: Trackers; Usage Data; various types of Data as specified in the privacy policy of the service
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TestFlight
Personal Data: Cookies; email address; Usage Data
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Google Analytics for Firebase
Personal Data: Application opens; device information; geography/region; In-app purchases; launches; number of sessions; operating systems; session duration; Usage Data
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Displaying content from external platforms
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Infrastructure monitoring
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Managing contacts and sending messages
Further information about the processing of Personal Data
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Branch Metrics
Branch Metrics is a service designed for mobile app analytics and deep-link sharing and can collect various information about your phone, highlighted in the Branch Metrics privacy policy. Werble uses Branch Metrics to facilitate deep-linking and help drive growth. Branch Metrics are based in the USA.
Branch Metrics Privacy Policy:
INTRODUCTION
Branch Metrics, Inc. and its subsidiaries, and any parent and affiliated companies ("Branch Metrics", "us" or "we") offers a sharing and analytics platform to enable mobile application developers (our “Clients”) to promote their Apps and to derive additional insights into how people that use the Internet (“Users”) download and utilize those Apps.
Branch Metrics recognizes that privacy is an important issue, so we design and operate our services with the protection of your privacy in mind. This privacy policy ("Policy") explains how information is collected and used pursuant to offering our products and services (the "Branch Metrics Services" or “Services”). This Policy also explains how information is collected and used in connection with our corporate website located at www.branch.io (the “Website”).
WHAT INFORMATION DOES BRANCH METRICS COLLECT?
The Website: What we collect from Clients
Branch Metrics collects personally identifiable information (“PII”) via the Website. PII is information that may be used to identify or contact a unique individual. For example, when Clients register to use our Services, we ask them to provide us with PII including first and last name, email address, and telephone number. To the extent that we charge a fee for the Services, we may also collect billing and payment information from Clients. We also require Clients to setup a user ID and unique password for account security purposes. Clients also have the option of uploading a profile photo and adding other team members to their account. This account information enables us to setup an account for Clients, to provide the Services, and to otherwise manage Client accounts. We may also use the information to notify Clients about updates to our Services and provide them with access to special promotions. We offer a mechanism to opt-out from marketing related emails.
The Website: What we collect from Users that visit the Website
While it is not necessary to provide PII to simply visit our Website, some Users may provide PII to Branch Metrics by sending us an email or filling out an online form on the Website. We generally use this information to answer their question and may store that information for our record keeping purposes.
We also collect non-personally identifiable information (“Non-PII”) via the Website from Users, including Clients. Non-PII is information that cannot by itself be used to identify a particular person or entity, and may include your IP host address, pages viewed, browser type, Internet browsing and usage habits, Internet Service Provider, domain name, the time/date of your visit to this Website, the referring URL and your computer’s operating system. We use the Non-PII collected via the Website to help administer the Website.
We automatically collect information using "cookies" and Web beacons on the Website. Cookies are small data files stored on your hard drive by a website and web beacons are electronic images that may be used on our Website or in our emails. Among other things, cookies help us improve your experience on the Website as well as our marketing activities. We use cookies to see which areas and features are popular and to count visits to our Website. Most web browsers are set to accept cookies by default. If you prefer, you can choose to set your browser to remove cookies and to reject cookies. Removing or rejecting cookies could negatively impact your experience on the Website. For more information about cookies and web beacons, please visit http://www.allaboutcookies.org/.
The Branch Metrics Services: Overview
Branch Metrics offers a self-serve tool that enables our Clients to create customizable and sharable “deep links” that provide Clients with additional insights into how Users download and utilize our Clients’ mobile Apps. A deep link is a hyperlink that enables the Service to track User activity beyond shares and through installs. Users encounter the Branch Service’s deep links in multiple ways, including: dynamically inside a mobile App, via SMS or email when Clients send links directly to their customers and prospects or when Users send other Users links directly, and via social networking platforms like Facebook and LinkedIn when Clients (or other Users) share our link socially. Our Service enables Clients to recognize mobile devices over time in order to ascertain whether a device that clicked one of our deep links is likely to be the same device that installed a particular mobile App. Our Service’s ability to recognize devices over time enables our Clients to help customize User App experiences, conduct analytics and better understand the effectiveness of their marketing campaigns.
Information Collected via Branch Metrics deep links
When a User clicks onto a deep link created via our Service by a Client, certain information is collected about that User’s mobile device. Most of this information is considered Non-PII, including: the mobile platform, SDK version, timestamp, API key (identifier for application), application version, device identifier, iOS Identifier for Advertising, iOS Identifier for Vendors, Android Advertiser ID, IP address, the device model, manufacturer and device O/S, session start/stop time, mobile network code, network status (WiFi, etc.). We may also use persistent cookies to help us collect or store this information. Our cookies can be deleted or rejected through the browser settings of the User’s device. Branch Metrics utilizes any combination of this data to help us identify a User's device(s) pursuant to providing the Service.
Clients may also pass custom data points to Branch pursuant to providing the Services such as the ad campaign name or information used to customize your experience with an App post install. The type of custom information shared via our Service is ultimately determined by our Clients. We strongly encourage Clients not to share sensitive information such as credit card or password information via our Service.
Information Collected post App Install
When a User installs and opens a mobile App that contains the Branch SDK, the Service collects the same information from the device described above (i.e., IP address, O/S and O/S version, Etc.) and ascertains whether it is likely that the same device that previously clicked on a deep link is the same device that installed and downloaded that particular App. If our technology has a reasonable level of confidence that it is the same device, the Service merges the information collected prior to the App being installed with the information collected post App install. This enables our Clients to better understand which deep links are effective, enables them to better understand their advertising and marketing programs and enables them to customize their User’s experience with their Apps.
Data Integrity
We process information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.
OUR CLIENTS’ USE OF INFORMATION
Our Clients generally use the information collected via the Service to better understand their App marketing programs, to better understand how Users discover their Apps, and to customize their Users’ app experiences. For example, a retailer might want to direct some of their Users to the section of the App that offers shoes, while directing other Users to the section of the App that offers shirts. Some App developers might even want to place shoes into an App’s shopping cart for Users that indicated a strong interest in buying a particular pair of shoes prior to downloading that App. We require that our Clients utilize our Service responsibly and in accordance with our Terms and Conditions of Service. Branch Metrics is not responsible for the data practices of any of our Clients. Each Client’s practices are subject to each Client’s individual privacy policies. Users should review the privacy policy of any company prior to sharing their information.
BRANCH METRICS’ USE OF INFORMATION
Branch Metrics reserves the right to use the information in our possession for the following purposes: (1) to fulfill Clients and prospective Clients’ requests for the Services; (2) to improve our Website and Services; (3) to contact Clients and Uses to answer questions or resolve problems; (4) to send information about Branch Metrics Services including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages; (5) to communicate with you about products and services offered by Branch Metrics and our selected partners; (6) to conduct research; (7) to create analytics products and services; and (8) to make the Website easier to use by reducing the need for Clients and Users to enter information.
Branch Metrics may also utilize information collected via the Website or the Service to better understand how Users come to download certain mobile Apps, what types of Apps are popular, what characteristics Users of certain Apps may have in common, and the connections between Users’ devices.
OPT-OUT – YOUR CHOICE MECHANISMS
Mobile O/S Choice Mechanisms and Do Not Track
Branch Metrics recognizes a number of consumer choice mechanisms. This includes the mobile device settings for Android and Apple iOS devices as well as Do Not Track signals coming from Internet browsers. These choice mechanisms generally restrict Branch Metrics ability to target advertising messages, which is not currently part of our Services.
To exercise the mobile device settings opt-out, please visit the privacy settings of your Android or iOS device and select “limit ad tracking” (Apple iOS) or “opt-out of interest based ads” (Android). Where Branch Metrics is able to see that such a selection has been made, we will not use information collected from that device to target advertising on mobile applications.
To exercise the Do Not Track settings, please visit the privacy settings of your browser. Where Branch Metrics is able to see that such a selection has been made, we will not use information collected from that device to target advertising on that browser.
Opt-out from promotional emails
In addition, you can opt-out of receiving 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 certain updates about your account and/or use of the Services.
UPDATING YOUR INFORMATION AND CONTACT PREFERENCES
We provide Clients with a mechanism to access, review and update information via the Website. If you wish to review or update your information, please visit branch.io and login using the user name and password you created. Next, please select "Account” which can be found in the lower left corner of the dashboard screen. If you would like to delete your account, please email info@branch.io.
In addition, you can opt-out of receiving 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 account. Under California law, California residents who have an established business relationship with us may choose to opt-out of the disclosure of personal information about them to third parties for such third parties' direct marketing purposes. As detailed above, our policy is not to disclose personal information collected online to a third party for direct marketing purposes without your approval. If you choose to opt- out at any time after granting approval, email privacy@branchmetrics.io.
HOW WE SHARE INFORMATION WITH OTHERS, ONWARD TRANSFER
Except as described in this policy, Branch Metrics does not rent, sell, or share personally identifiable information collected on Websites or through the Branch Metrics Services with other people or nonaffiliated companies unless we have your consent, or under the following circumstances:
With third party vendors, consultants and other service providers who work for us and need access to your information to do that work. These third parties are prohibited from using the information for purposes other than performing services for us;
To comply with laws or to respond to lawful requests and legal process and in order to investigate, prevent, or take action regarding suspected, or actual prohibited activities, including but not limited to fraud and situations involving potential threats to the physical safety of any person;
To protect the rights and property of Branch Metrics, our agents, customers, users, and others including to enforce our agreements, policies and terms of use;
In connection with or during negotiation of any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company.
We may also share aggregated or anonymized information without restriction.
WE SECURE YOUR PERSONAL INFORMATION
The security of your information is important to us, including but not limited to the PII collected via the Website and Services. Branch Metrics has implemented a number of technical, administrative, and physical safeguards to help protect the information on our servers against unauthorized access, alteration, disclosure or destruction. No method of transmission over the Internet or method of electronic storage is 100% secure; therefore, while the company strives to use commercially acceptable means to protect your information, it cannot guarantee absolute security.
OUR POLICY REGARDING CHILDREN
Neither the Branch Metrics Website nor the Services are directed to children. We do not knowingly collect PII from anyone under the age of 13. If you are under 13, please do not attempt to register or send any information about yourself to us, including your name, address, telephone number, or email address. No one under the age of 13 may provide any personal information to us. In the event that we learn that we have collected PII from a child under age 13 we will take reasonable steps to delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of 13, please contact us at privacy@branchmetrics.io.
THIRD PARTY TOOLS/ANALYTICS ON THE WEBSITE
The Website utilizes third party tracking tools from third party service providers, which may enable these third parties to analyze our Website traffic for analytics purposes. The Website also includes social media tools, such as the Facebook Like button. Such tools may collect information such as your IP address and which page you are visiting on our Website, and may set a cookie to enable the feature to function properly or to tailor or personalize the services of the company providing the feature. All of these tools are hosted by the third parties who provide them, and your interactions with these features are governed by the privacy policy of the company providing it.
INTERNATIONAL DATA TRANSFERS
All information we have is stored on servers located in the United States. In the process of providing our Website or the Services, we may transfer information across borders from your country or jurisdiction into the United States. Branch continues to adhere to the underlying privacy principles of the US-EU and US- Swiss Safe Harbor programs for personal information received from the EU and Switzerland as administered by the U.S. Department of Commerce (http://export.gov/safeharbor/). With the exception of data transfers from the EEU and Switzerland, by providing Branch with your personal information, you hereby consent to the transfer of information to the U.S.
QUESTIONS, CHANGES TO THIS PRIVACY POLICY
We may change this Policy at any time. We will post all changes to this Policy on this page and will indicate at the top of the page the modified policy's effective date. If you have any questions or suggestions regarding this Policy, please contact us at:
Attn: Privacy Officer
privacy@branchmetrics.io
Privacy Complaints by European Union and Swiss Citizens
In compliance with the U.S.-EU and U.S.-Swiss Safe Harbor Principles, Branch Metrics commits to resolve complaints about your privacy and our collection or use of your personal information. European Union and Swiss citizens with inquiries or complaints regarding this privacy policy should first contact us at privacy@branchmetrics.io.
We have further committed to refer unresolved privacy complaints under the Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU Safe Harbor, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by the privacy department at Branch Metrics, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.
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Owner and Data Controller
Horsie In The Hedge Limited - Waynflete House 139 Eastgate, Louth, Lincolnshire, LN11 9QQ
Owner contact email: privacy@werbleapp.com
Full policy
Owner and Data Controller
Horsie In The Hedge Limited - Waynflete House 139 Eastgate, Louth, Lincolnshire, LN11 9QQ
Owner contact email: privacy@werbleapp.com
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are:
Usage Data; Trackers; email address; device information; geography/region; number of sessions; session duration; In-app purchases; Application opens; launches; operating systems.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Analytics, Displaying content from external platforms, Infrastructure monitoring and Managing contacts and sending messages.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Facebook Analytics for Apps (Facebook, Inc.)
Facebook Analytics for Apps is an analytics service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing,
Personal Data processed: Trackers; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
TestFlight (Apple Inc.)
TestFlight is a beta testing service provided by Apple Inc.
Personal Data processed: Cookies; email address; Usage Data.
Place of processing: US – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
Google Analytics for Firebase
Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
In order to understand Google's use of Data, consult Google's partner policy.
Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.
This Application uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service.
Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.
Personal Data processed: Application opens; device information; geography/region; In-app purchases; launches; number of sessions; operating systems; session duration; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of Personal Information collected according to the CCPA: commercial information; internet or other electronic network activity information; geolocation data.
This processing constitutes:
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Displaying content from external platforms
This type of services allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
YouTube video widget (Google Inc.)
YouTube is a video content visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: US – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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Infrastructure monitoring
This type of services allows this Application to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Application.
Instabug (Instabug, Inc.)
Instabug is a monitoring service provided by Instabug, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Firebase Cloud Messaging
Firebase Cloud Messaging is a message sending service provided by Google Ireland Limited or by Google LLC, depending on how the Owner manages the Data processing. Firebase Cloud Messaging allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or specific topics or User segments.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United Kingdom – Privacy Policy; United Kingdom – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a sale in California
- a Sharing in California
Further information about the processing of Personal Data
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Branch Metrics
Branch Metrics is a service designed for mobile app analytics and deep-link sharing and can collect various information about your phone, highlighted in the Branch Metrics privacy policy. Werble uses Branch Metrics to facilitate deep-linking and help drive growth. Branch Metrics are based in the USA.
Branch Metrics Privacy Policy:
INTRODUCTION
Branch Metrics, Inc. and its subsidiaries, and any parent and affiliated companies ("Branch Metrics", "us" or "we") offers a sharing and analytics platform to enable mobile application developers (our “Clients”) to promote their Apps and to derive additional insights into how people that use the Internet (“Users”) download and utilize those Apps.
Branch Metrics recognizes that privacy is an important issue, so we design and operate our services with the protection of your privacy in mind. This privacy policy ("Policy") explains how information is collected and used pursuant to offering our products and services (the "Branch Metrics Services" or “Services”). This Policy also explains how information is collected and used in connection with our corporate website located at www.branch.io (the “Website”).
WHAT INFORMATION DOES BRANCH METRICS COLLECT?
The Website: What we collect from Clients
Branch Metrics collects personally identifiable information (“PII”) via the Website. PII is information that may be used to identify or contact a unique individual. For example, when Clients register to use our Services, we ask them to provide us with PII including first and last name, email address, and telephone number. To the extent that we charge a fee for the Services, we may also collect billing and payment information from Clients. We also require Clients to setup a user ID and unique password for account security purposes. Clients also have the option of uploading a profile photo and adding other team members to their account. This account information enables us to setup an account for Clients, to provide the Services, and to otherwise manage Client accounts. We may also use the information to notify Clients about updates to our Services and provide them with access to special promotions. We offer a mechanism to opt-out from marketing related emails.
The Website: What we collect from Users that visit the Website
While it is not necessary to provide PII to simply visit our Website, some Users may provide PII to Branch Metrics by sending us an email or filling out an online form on the Website. We generally use this information to answer their question and may store that information for our record keeping purposes.
We also collect non-personally identifiable information (“Non-PII”) via the Website from Users, including Clients. Non-PII is information that cannot by itself be used to identify a particular person or entity, and may include your IP host address, pages viewed, browser type, Internet browsing and usage habits, Internet Service Provider, domain name, the time/date of your visit to this Website, the referring URL and your computer’s operating system. We use the Non-PII collected via the Website to help administer the Website.
We automatically collect information using "cookies" and Web beacons on the Website. Cookies are small data files stored on your hard drive by a website and web beacons are electronic images that may be used on our Website or in our emails. Among other things, cookies help us improve your experience on the Website as well as our marketing activities. We use cookies to see which areas and features are popular and to count visits to our Website. Most web browsers are set to accept cookies by default. If you prefer, you can choose to set your browser to remove cookies and to reject cookies. Removing or rejecting cookies could negatively impact your experience on the Website. For more information about cookies and web beacons, please visit http://www.allaboutcookies.org/.
The Branch Metrics Services: Overview
Branch Metrics offers a self-serve tool that enables our Clients to create customizable and sharable “deep links” that provide Clients with additional insights into how Users download and utilize our Clients’ mobile Apps. A deep link is a hyperlink that enables the Service to track User activity beyond shares and through installs. Users encounter the Branch Service’s deep links in multiple ways, including: dynamically inside a mobile App, via SMS or email when Clients send links directly to their customers and prospects or when Users send other Users links directly, and via social networking platforms like Facebook and LinkedIn when Clients (or other Users) share our link socially. Our Service enables Clients to recognize mobile devices over time in order to ascertain whether a device that clicked one of our deep links is likely to be the same device that installed a particular mobile App. Our Service’s ability to recognize devices over time enables our Clients to help customize User App experiences, conduct analytics and better understand the effectiveness of their marketing campaigns.
Information Collected via Branch Metrics deep links
When a User clicks onto a deep link created via our Service by a Client, certain information is collected about that User’s mobile device. Most of this information is considered Non-PII, including: the mobile platform, SDK version, timestamp, API key (identifier for application), application version, device identifier, iOS Identifier for Advertising, iOS Identifier for Vendors, Android Advertiser ID, IP address, the device model, manufacturer and device O/S, session start/stop time, mobile network code, network status (WiFi, etc.). We may also use persistent cookies to help us collect or store this information. Our cookies can be deleted or rejected through the browser settings of the User’s device. Branch Metrics utilizes any combination of this data to help us identify a User's device(s) pursuant to providing the Service.
Clients may also pass custom data points to Branch pursuant to providing the Services such as the ad campaign name or information used to customize your experience with an App post install. The type of custom information shared via our Service is ultimately determined by our Clients. We strongly encourage Clients not to share sensitive information such as credit card or password information via our Service.
Information Collected post App Install
When a User installs and opens a mobile App that contains the Branch SDK, the Service collects the same information from the device described above (i.e., IP address, O/S and O/S version, Etc.) and ascertains whether it is likely that the same device that previously clicked on a deep link is the same device that installed and downloaded that particular App. If our technology has a reasonable level of confidence that it is the same device, the Service merges the information collected prior to the App being installed with the information collected post App install. This enables our Clients to better understand which deep links are effective, enables them to better understand their advertising and marketing programs and enables them to customize their User’s experience with their Apps.
Data Integrity
We process information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.
OUR CLIENTS’ USE OF INFORMATION
Our Clients generally use the information collected via the Service to better understand their App marketing programs, to better understand how Users discover their Apps, and to customize their Users’ app experiences. For example, a retailer might want to direct some of their Users to the section of the App that offers shoes, while directing other Users to the section of the App that offers shirts. Some App developers might even want to place shoes into an App’s shopping cart for Users that indicated a strong interest in buying a particular pair of shoes prior to downloading that App. We require that our Clients utilize our Service responsibly and in accordance with our Terms and Conditions of Service. Branch Metrics is not responsible for the data practices of any of our Clients. Each Client’s practices are subject to each Client’s individual privacy policies. Users should review the privacy policy of any company prior to sharing their information.
BRANCH METRICS’ USE OF INFORMATION
Branch Metrics reserves the right to use the information in our possession for the following purposes: (1) to fulfill Clients and prospective Clients’ requests for the Services; (2) to improve our Website and Services; (3) to contact Clients and Uses to answer questions or resolve problems; (4) to send information about Branch Metrics Services including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages; (5) to communicate with you about products and services offered by Branch Metrics and our selected partners; (6) to conduct research; (7) to create analytics products and services; and (8) to make the Website easier to use by reducing the need for Clients and Users to enter information.
Branch Metrics may also utilize information collected via the Website or the Service to better understand how Users come to download certain mobile Apps, what types of Apps are popular, what characteristics Users of certain Apps may have in common, and the connections between Users’ devices.
OPT-OUT – YOUR CHOICE MECHANISMS
Mobile O/S Choice Mechanisms and Do Not Track
Branch Metrics recognizes a number of consumer choice mechanisms. This includes the mobile device settings for Android and Apple iOS devices as well as Do Not Track signals coming from Internet browsers. These choice mechanisms generally restrict Branch Metrics ability to target advertising messages, which is not currently part of our Services.
To exercise the mobile device settings opt-out, please visit the privacy settings of your Android or iOS device and select “limit ad tracking” (Apple iOS) or “opt-out of interest based ads” (Android). Where Branch Metrics is able to see that such a selection has been made, we will not use information collected from that device to target advertising on mobile applications.
To exercise the Do Not Track settings, please visit the privacy settings of your browser. Where Branch Metrics is able to see that such a selection has been made, we will not use information collected from that device to target advertising on that browser.
Opt-out from promotional emails
In addition, you can opt-out of receiving 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 certain updates about your account and/or use of the Services.
UPDATING YOUR INFORMATION AND CONTACT PREFERENCES
We provide Clients with a mechanism to access, review and update information via the Website. If you wish to review or update your information, please visit branch.io and login using the user name and password you created. Next, please select "Account” which can be found in the lower left corner of the dashboard screen. If you would like to delete your account, please email info@branch.io.
In addition, you can opt-out of receiving 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 account. Under California law, California residents who have an established business relationship with us may choose to opt-out of the disclosure of personal information about them to third parties for such third parties' direct marketing purposes. As detailed above, our policy is not to disclose personal information collected online to a third party for direct marketing purposes without your approval. If you choose to opt- out at any time after granting approval, email privacy@branchmetrics.io.
HOW WE SHARE INFORMATION WITH OTHERS, ONWARD TRANSFER
Except as described in this policy, Branch Metrics does not rent, sell, or share personally identifiable information collected on Websites or through the Branch Metrics Services with other people or nonaffiliated companies unless we have your consent, or under the following circumstances:
With third party vendors, consultants and other service providers who work for us and need access to your information to do that work. These third parties are prohibited from using the information for purposes other than performing services for us;
To comply with laws or to respond to lawful requests and legal process and in order to investigate, prevent, or take action regarding suspected, or actual prohibited activities, including but not limited to fraud and situations involving potential threats to the physical safety of any person;
To protect the rights and property of Branch Metrics, our agents, customers, users, and others including to enforce our agreements, policies and terms of use;
In connection with or during negotiation of any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company.
We may also share aggregated or anonymized information without restriction.
WE SECURE YOUR PERSONAL INFORMATION
The security of your information is important to us, including but not limited to the PII collected via the Website and Services. Branch Metrics has implemented a number of technical, administrative, and physical safeguards to help protect the information on our servers against unauthorized access, alteration, disclosure or destruction. No method of transmission over the Internet or method of electronic storage is 100% secure; therefore, while the company strives to use commercially acceptable means to protect your information, it cannot guarantee absolute security.
OUR POLICY REGARDING CHILDREN
Neither the Branch Metrics Website nor the Services are directed to children. We do not knowingly collect PII from anyone under the age of 13. If you are under 13, please do not attempt to register or send any information about yourself to us, including your name, address, telephone number, or email address. No one under the age of 13 may provide any personal information to us. In the event that we learn that we have collected PII from a child under age 13 we will take reasonable steps to delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of 13, please contact us at privacy@branchmetrics.io.
THIRD PARTY TOOLS/ANALYTICS ON THE WEBSITE
The Website utilizes third party tracking tools from third party service providers, which may enable these third parties to analyze our Website traffic for analytics purposes. The Website also includes social media tools, such as the Facebook Like button. Such tools may collect information such as your IP address and which page you are visiting on our Website, and may set a cookie to enable the feature to function properly or to tailor or personalize the services of the company providing the feature. All of these tools are hosted by the third parties who provide them, and your interactions with these features are governed by the privacy policy of the company providing it.
INTERNATIONAL DATA TRANSFERS
All information we have is stored on servers located in the United States. In the process of providing our Website or the Services, we may transfer information across borders from your country or jurisdiction into the United States. Branch continues to adhere to the underlying privacy principles of the US-EU and US- Swiss Safe Harbor programs for personal information received from the EU and Switzerland as administered by the U.S. Department of Commerce (http://export.gov/safeharbor/). With the exception of data transfers from the EEU and Switzerland, by providing Branch with your personal information, you hereby consent to the transfer of information to the U.S.
QUESTIONS, CHANGES TO THIS PRIVACY POLICY
We may change this Policy at any time. We will post all changes to this Policy on this page and will indicate at the top of the page the modified policy's effective date. If you have any questions or suggestions regarding this Policy, please contact us at:
Attn: Privacy Officer
privacy@branchmetrics.io
Privacy Complaints by European Union and Swiss Citizens
In compliance with the U.S.-EU and U.S.-Swiss Safe Harbor Principles, Branch Metrics commits to resolve complaints about your privacy and our collection or use of your personal information. European Union and Swiss citizens with inquiries or complaints regarding this privacy policy should first contact us at privacy@branchmetrics.io.
We have further committed to refer unresolved privacy complaints under the Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU Safe Harbor, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by the privacy department at Branch Metrics, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.
This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Further information for Users
in Switzerland
This section applies to Users in Switzerland, and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy.
Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the personal data, if any, the retention period and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.
The rights of Users according to the Swiss Federal Act on Data Protection
Users may exercise certain rights regarding their Data within the limits of law, including the following:
- right of access to Personal Data;
- right to object to the processing of their Personal Data (which also allows Users to demand that processing of Personal Data be restricted, Personal Data be deleted or destroyed, specific disclosures of Personal Data to third parties be prohibited);
- right to receive their Personal Data and have it transferred to another controller (data portability);
- right to ask for incorrect Personal Data to be corrected.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible, providing Users with the information required by law.
Further information for Users
in Brazil
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users in Brazil (Users are referred to below, simply as “you”, “your”, “yours”), according to the "Lei Geral de Proteção de Dados" (the "LGPD"), and for such Users, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal information“ as it is defined in the LGPD.
The grounds on which we process your personal information
We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:
- your consent to the relevant processing activities;
- compliance with a legal or regulatory obligation that lies with us;
- the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
- studies conducted by research entities, preferably carried out on anonymized personal information;
- the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
- the exercising of our rights in judicial, administrative or arbitration procedures;
- protection or physical safety of yourself or a third party;
- the protection of health – in procedures carried out by health entities or professionals;
- our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
- credit protection.
To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.
Categories of personal information processed
To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.
Why we process your personal information
To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
Your Brazilian privacy rights, how to file a request and our response to your requests
Your Brazilian privacy rights
You have the right to:
- obtain confirmation of the existence of processing activities on your personal information;
- access to your personal information;
- have incomplete, inaccurate or outdated personal information rectified;
- obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
- obtain information on the possibility to provide or deny your consent and the consequences thereof;
- obtain information about the third parties with whom we share your personal information;
- obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
- obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
- revoke your consent at any time;
- lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
- oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
- request clear and adequate information regarding the criteria and procedures used for an automated decision; and
- request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.
You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.
How to file your request
You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.
How and when we will respond to your request
We will strive to promptly respond to your requests.
In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.
In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.
You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.
In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.
In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request — except in cases where such communication is proven impossible or involves disproportionate effort on our side.
Transfer of personal information outside of Brazil permitted by the law
We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:
- when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
- when the transfer is necessary to protect your life or physical security or those of a third party;
- when the transfer is authorized by the ANPD;
- when the transfer results from a commitment undertaken in an international cooperation agreement;
- when the transfer is necessary for the execution of a public policy or legal attribution of public service;
- when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.
Further information for Users
in the United States
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana.
For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term Personal Information.
Notice at collection
The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.
While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.
-
Identifiers
Personal Information collected or disclosed:
Usage data, Various types of data as specified in the privacy policy of the service, Trackers, Cookies, Email address
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Facebook, Inc., Apple Inc.
-
Internet or other electronic network activity information
Personal Information collected or disclosed:
Usage data, Various types of data as specified in the privacy policy of the service, Trackers, Cookies, Email address, Device information, Geography/region, Number of sessions, Session duration, In-app purchases, Application opens, Launches, Operating systems
Purposes:
- Analytics
- Displaying content from external platforms
- Infrastructure monitoring
- Managing contacts and sending messages
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Facebook, Inc., Google Inc., Apple Inc., Instabug, Inc., Google Ireland Limited, Google LLC
-
Commercial information
Personal Information collected or disclosed:
Usage data, Device information, Geography/region, Number of sessions, Session duration, In-app purchases, Application opens, Launches, Operating systems
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Google LLC
-
Geolocation data
Personal Information collected or disclosed:
Usage data, Device information, Geography/region, Number of sessions, Session duration, In-app purchases, Application opens, Launches, Operating systems
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Google LLC
ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.
To know more about your rights in particular to opt out of certain processing activities you can refer to the “Your privacy rights under US state laws” section of our privacy policy.
For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy.
We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.
What are the sources of the Personal Information we collect?
We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use this Application.
For example, you directly provide your Personal Information when you submit requests via any forms on this Application. You also provide Personal Information indirectly when you navigate this Application, as Personal Information about you is automatically observed and collected.
Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.
Your privacy rights under US state laws
You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:
- the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
- the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
- the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
- the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
- the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
- the right to non-discrimination.
Additional rights for Users residing in California
In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have
- The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
- The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.
Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon and Montana
In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas and Oregon, you have
- The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
- The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
Additional rights for users residing in Utah
In addition to the rights listed above common to all Users in the United States, as a User residing in Utah, you have
- The right to opt out of the processing of your Personal Information for Targeted Advertising;
- The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
How to exercise your privacy rights under US state laws
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How to exercise your rights to opt out
In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on this Application.
If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.
Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).
We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
/ Personal Information (or Information)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Sensitive Personal Information
Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law.
Usage Data
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
This Application
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Application as described in the relative terms (if available) and on this site/application.
Sale
Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information.
Sharing
Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's Personal Information by the business to a third party for cross-context behavioral advertising, whether for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged, as defined by the California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information.
Targeted advertising
Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations.
This privacy policy relates solely to this Application, if not stated otherwise within this document.