AppsFlyer provides attribution and marketing analytics services (“Services“) that enable advertisers and developers (collectively, “Customer(s)“) to: (i) measure and analyze the effectiveness of their marketing campaigns by understanding which marketing campaigns contributed to the download/installation of their mobile applications (“Applications“) or such other conversion metric (e.g. relaunch of Application); and (ii) measure and analyze certain events and actions within their Application or websites, such as in-app purchases made by End Users (as defined below). The Services also help our Customers identify and protect against fraudulent behavior related to their marketing campaigns.
- END USER DATA RECEIVED AND PROCESSED BY APPSFLYER
When a Customer uses the Services, the following End User information may be received and processed by AppsFlyer (collectively, “End User Data”).
- “Technical Information”: this refers to technical information related to an End User’s mobile device or computer, such as: browser type, device type and model, CPU, system language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier.
- “Technical Identifiers”: this refers to various unique identifiers that generally only identify a computer, device, browser or Application. For example, IP address (which may also provide general location information), User agent, IDFA (identifier for advertisers), Android ID (in Android devices); Google Advertiser ID, Customer issued user ID and other similar unique identifiers.
- “Engagement Information”: this refers to information relating to the Customer’s ad campaigns and End User actions, such as: clicks on Customer ads, ad impressions viewed, audiences or segments to which an ad campaign is attributed, the type of ads and the webpage or Application from which such ads were displayed, the webpages on Customer’s website visited by an End User, the URL from the referring website, downloads and installations of Applications, and other interactions, events and actions Customers choose to measure and analyze within their Application or website (e.g. add to cart, in-app purchases made, clicks, engagement time etc.).
- While End User Data does not generally contain any information that directly identifies an individual, such as names, addresses, credit cards or other similarly regulated financial information, health information, or any other type of sensitive personal information (“PII“), we acknowledge that under certain jurisdictions the End User Data we do receive when a Customer uses the Services may be deemed personal data and therefore, where applicable, will be treated as such. Within the scope of the engagement between Customers and AppsFlyer, Customers are contractually prohibited from collecting PII, unless otherwise agreed by AppsFlyer. However, Customers have sole control over their properties (including their websites and Application) and configuration of the Services and thus Customers have the technical ability to configure the Services to collect PII. This includes, for example, a Customer using an End User’s email address as a Customer issued user ID Technical Identifier. If a Customer has configured the Services to collect PII then we may receive and process such data.
- REGISTRATION INFORMATION RECEIVED AND PROCESSED BY APPSFLYER
When a Customer registers to use the Services, we may collect certain information related to such Customer (“Registration Information” and together with the End User Data, “Customer Data”), including Customer name and Customer details, billing information and names and contact details of Customer employees and representatives who are using the Services (e.g. email, phone number and address). When a Customer uses the Services, AppsFlyer may also collect certain log data, such as IP address from which a Customer is connecting to the Services, information related to the device being used to connect to the Services (e.g. browser type, device type, OS version) and the features and functions of the Services used by the Customer (“Log Data”).
- HOW DATA IS COLLECTED
Customer Data may be collected through various methods, including:
- When provided voluntarily (e.g. Customer’s Registration Information).
- From the various advertising networks and third parties that are used by the Customer in connection with the measurement and analysis of Customer’s marketing campaigns and that have partnered with AppsFlyer (“Partners”).
- HOW DATA IS USED BY APPSFLYER
- When AppsFlyer receives End User Data from a Customer, it uses such End User Data as follows:
- to provide such Customer with the Services they have subscribed for. Such services may include, without limitation, attribution, analytics and ad fraud protection services. Please visit https://www.appsflyer.com/product/overview/ for more information regarding the Services.
- to establish: (i) matches between devices used by an End User; and (ii) a device fraud rating (such matched data and fraud rating data, collectively, the, “Platform Data”) in order to ensure more accurate attribution measurement and ad fraud protection for Customers using the Services. Platform Data does not contain PII such as End User names, physical addresses, phone numbers or other similar personal data that can directly identify an individual.
- With regards to Registration Information and Log Data, we use such information to authenticate login to the Services, to communicate with Customer and to process any payments in connection with the Services. Additionally, we may use: (i) Registration Information to inform Customer of any updates to the Services, including new features and functionalities; and (ii) Log Data to understand how Customers are using the Services so that we may efficiently audit, maintain and improve the Services provided to Customers.
- AppsFlyer may use information derived from the aggregation of End User Data and/or Log Data with other data for research and analytics purposes and improvement and marketing of the Services (“Aggregated Data”). Aggregated Data shall be anonymous and in no way reveal the identity of the Customer or any End User.
- When AppsFlyer receives End User Data from a Customer, it uses such End User Data as follows:
- SHARING DATA
AppsFlyer does not share or disclose Customer Data with any third party, except:
Upon our Customer’s request– (e.g. to Partners);
- To our subsidiaries and global branches as necessary to help us support and maintain the Services provided to Customers;
- To our service providers who help to support our Services – such as data hosting providers and payment processors; Transfers to subsequent third parties are covered by the service agreements with our Customers. These companies are authorized to use your personal information only as necessary to provide these services to us.
- When legally required (e.g. court orders or other lawful requests by public authorities), including to meet national security or law enforcement requirements;
- To respond to, or prevent, fraud or to protect the safety of AppsFlyer, its Customers, End Users or the public;
- As part of any merger or acquisition of AppsFlyer, in which case End User Data may be transferred to the surviving or acquiring entity.
- CROSS BORDER TRANSFERS AND EU-US AND SWISS-US PRIVACY SHIELD
AppsFlyer may need to transfer Customer Data to countries other than the country from which the Data originated. Any such transfer shall be done in compliance with all applicable laws. With regards to the collection, use and retention of personal data transferred from the European Economic Area or Switzerland to the United States, AppsFlyer Inc. complies with the EU-U.S. and Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce. To learn more, please click here
- PROTECTING DATA AND RETENTION
AppsFlyer will not retain: (i) End User Data for more than twenty four months except where otherwise directed by Customers or required or allowed by law; and (ii) Registration Information, Log Data or Platform Data for more time than is needed to serve the legitimate business need for which it was collected.
- RELATIONSHIP, LAWFUL BASIS AND END USER CHOICES
Under the laws of certain jurisdictions, when processing End User Data in connection with the provision of Services to a Customer, AppsFlyer is deemed a ‘data processor’ while its Customers are deemed ‘data controllers’.
Therefore, End Users should closely review the Privacy Policies of the Applications and websites they use in order to learn about the privacy practices of our Customers.
The laws of certain jurisdictions may provide End Users with various rights in connection with the processing of End User Data, including:
- The right to withdraw any previously provided consent;
- The right to access certain information about you that we process;
- The right to have us correct or update any Personal Information;
- The right to have certain Information erased;
- The right to have us temporarily block our processing of certain Information;
- The right to have Information exported into common machine-readable format;
- The right to object to our processing of Information in cases of direct marketing, or when we rely on legitimate interests as our lawful basis to process your information; and
- The right to lodge a complaint with the appropriate data protection authority.
Where AppsFlyer is deemed a data processor, End Users should contact our Customers to pursue any such legal data subject rights. AppsFlyer will cooperate with its Customers to support and comply with any such data subject rights requests.
Where AppsFlyer is deemed a data controller, End Users may exercise their rights by contacting AppsFlyer at: email@example.com. We will respond to your requests within a reasonable timeframe. Please note these rights may be limited in certain circumstances as provided by applicable law. In any event, AppsFlyer provides End Users with the ability to opt-out of being measured by the Services by emailing a request to firstname.lastname@example.org or by completing the form here. You may also send any question regarding your exercise of data subject rights to email@example.com.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
- UPDATES AND QUESTIONS
AppsFlyer – Attn: Legal Team/Data Protection Officer
14 Maskit St.
For the purposes of Article 27 of the General Data Protection Regulation, the representative within the EU of AppsFlyer is AppsFlyer Germany GmbH Kurfürstendamm 11, c/o WeWork, 10719 Berlin, Germany (contact firstname.lastname@example.org; +49-30-3119-9129)
Date: March 24, 2019.