APPLICATION PRIVACY POLICY

Last updated 1 December 2021

APPCAPITAL AG, a company registered at Baarerstrasse 78, 6300, Zug, Switzerland, together with companies in the same corporate group (hereinafter “AppCapital Group”), take your privacy seriously. Please, read carefully this Privacy Policy as it sets out our data processing practices with respect to your data collected via AppCapital Group App.
This Privacy Policy is an integral part of Our Terms and Conditions and refers to AppCapital Group Apps, hereinafter – the “App/ Apps/ AppCapital Group App/ AppCapital Group Apps”. All definitions used in this Privacy Policy (if not explicitly mentioned herein) shall have the same meaning as provided in Our Terms and Conditions.
“Advertising ID” means Apple Identifier for Advertisers (“IDFA”). These are unique identifiers for mobile device that advertisers use for personalized advertising. They are consistent across all mobile applications and thus allow cross-app tracking. Advertising IDs are non-permanent, non-personal identifiers, which are uniquely associated with your device.
“Device identifier” means device type, device model, device maker, device operating system and its language or other technical data like screen size or processor, or combination of this data available from a device for a developer for checking the device compatibility with a particular application.
“IP address” or “Internet Protocol Address” mean addresses assigned to computers connected to the Internet. Those addresses can be “dynamic” which means they change each time the computer connects to the Internet, or they can be “static” which means that they are fixed. When a computer requests a web page or other content on the Internet, it sends its IP address to the computer hosting that content asking the server to return the content to its IP address. Without the address, the server would not know where to send the content.
“Your (personal) data” in this Privacy Policy shall mean any data regarding You or users of the App, which identifies or allows to identify You.

1. ACCEPTANCE OF THIS PRIVACY POLICY
1.1. By using AppCapital Group App you express your acceptance of this Privacy Policy, as such Policy may be amended from time to time. Each time you use AppCapital Group App, you agree to our collection, use, storage, transfer and disclosure of the information that you provide as described in this Policy.
1.2. If you do not agree to be bound by this Privacy Policy then, please, do not use AppCapital Group App.

2. INFORMATION COLLECTED
2.1 Information We Collect
To use our App You need to enable Your camera. However, all images taken by your mobile phone camera shall be processed solely on your device and shall not be sent to our servers, i.e. we do not have access to such images (we will not collect, share or store them). We will ask for Your separate permissions to enable Your camera. If You change Your mind, You will be able to revoke the given permission any time afterwards by changing settings on Your Device or by e-mailing your request to app@appcapital.vc. However, please note that rejecting or switching off this permission might negatively affect the use of our Apps or even effect its full functionality.
2.1.2. AppCapital Group App is not able to identify a specific person and, therefore, cannot be considered as processing biometric information. However, in case the applicable law stipulates that images captured by the camera are considered as biometric identifiers, biometric information or similar legal category, hereby you express your informed written consent on their processing as described in this Policy.
2.1.3. When using our Apps we do not collect information, which identify or allows to identify you, unless you voluntarily provide us with such data (in particular, when communicating with our support team, leaving feedback re your experience with the Apps) or when certain parts of our Services ask you to provide personal information voluntarily (e.g. we process your email when you submit enquiries via AppCapital Group website or AppCapital Group App along with other information you deem necessary to provide or request). If you leave your email we may send you our updates (marketing communications), unless you opt-out receiving these messages from us by clicking “UNSUBSCRIBE” inside the message.
2.1.4. In case we start collecting other categories of your personal data, we shall first explain why we collect it and ask for your express consent for such collection and further processing.
2.1.5 In case we start collecting other categories of your personal data, we shall first explain why we collect it and ask for your express consent for such collection and further processing.
2.2 Information Collected by Third-Party Providers
2.2.1. For the purposes of attribution and tracking the performance of our advertising campaigns and applications, including their effectiveness, usage, installations and downloads, we engage advertising and analytics third party providers (hereinafter – Providers), currently the following Providers are being engaged:
Provider and its website
Amplitude https://amplitude.com/
Firebase https://firebase.google.com/
AppsFlyer https://www.appsflyer.com/ru/
Adapty https://adapty.io/
Qonversion https://qonversion.io/
AppMetrica appmetrica.yandex.ru/
Facebook facebook.com
Google google.com
Apphud https://apphud.com/
Adjust https://www.adjust.com/
Branch https://branch.io/
The lists of Providers licenses used may be amended from time to time, please refer to this Privacy Policy to obtain up-to-date information.
2.2.2. The Providers may collect the following personal information about users of the Devices: IP address, advertising IDs assigned by our Providers, browsing behavior and location data. Such information shall be collected directly by Providers and subsequently shall be shared with us. The Providers may combine such information with other personal information they have in their procession and may use it for targeted advertising, i.e. for showing the most relevant ads to You across Internet network.
2.2.3. Personal data mentioned in Clause 2.2.2 shall be collected based on our legitimate interest according to Clause 3.1.2. of this Privacy Policy. We will comply a case-by-case test to ensure eligibility of our legitimate interests, including necessity assessment and balancing test.
2.2.4. If you do not wish your data to be processed for receiving a personalized advertising and analytical purposes you may opt out as described in Clause 4.5 or if applicable simply turning off the switcher in the Settings menu in the App or you may send your request via app@appcapital.vc. We will erase your personal data and request our providers to do the same within 30 days upon your request.
2.2.5. Besides statistics data collected by the Providers, the data on how you are using the App will be accessible for us. These data will not be personalized or linked to device you are using. These data are needed to enable proper operation of the App, in particular to identify and fix the problems you are facing when using the App.
2.2.6. To enable operation of the App a specific identifier to the statistics and usage data may be generated by some Providers. This identifier is specific for each App (i.e. it is not the same across multiple applications, like advertising ID). This identifier permits us solely to identify that events of using the App belong to the same user, however does not let it possible to identify that user.
2.2.7. Other data about your Devices that do not permit direct association with you or other individuals, such as the operating system, settings, language, wireless network, mobile network information, software and hardware attributes may be also collected by our Providers.
2.2.8. Personally identifiable information about your online activities over time and across third-party websites or online services, is collected by our Providers which may share it with us. Our Providers generally do not respond to Do Not Track (DNT) signals or other mechanisms that provide you with the ability to exercise choice regarding the collection of such information. Nevertheless, if you want us not to use, or to stop using, such Providers in relation to You, please let us know via app@appcapital.vc

3. BASES FOR PROCESSING
3.1. The legal bases that we rely upon when processing your personal data are as follows:
3.1.1. Processing of your data, mentioned in Clause 2.1.1 , is required for the provision of Services to You.
3.1.2. Processing of your personal data as described in 2.1.3. (serving your request and sending marketing communications), 2.2.2. (data processing for analytics and ads personalization) is our legitimate interest to improve the performance of our business and provide you with information and services you request.
We pay special attention to your data protection rights making sure that your data protection rights are not overridden by our legitimate interests.
These legitimate interests are: (a) to ensure effective administration and management of your relationship with us; (b) to understand how you use our Services and how we can improve the customers usage experience; (c) understand and respond to your feedback; (d) to prevent, detect, or investigate unauthorized use of our Services; (e) ensure we comply with law and our policies; (f) anti-fraud reasons; and (g) manage any disputes and accidents and take legal or other professional advice.
3.1.3. Contractual necessity covers information that is processed by us in order to provide you with service that you have requested – and that we have agreed – to provide to you.
3.1.4. Legal obligation covers information that is processed by us to comply with a legal obligation.
3.2. We will ask for your separate permissions to use your camera and microphone, as well as for sending push notifications to you. If you change your mind re permissions granted, you will be able to revoke them at any time afterwards by changing settings on your Device. However, please note that rejecting or switching off these permissions shall negatively affect the use of AppCapital Group App: AppCapital Group App will lose its full functionality.

4. PURPOSES OF PROCESSING
4.1. We will process data collected under this Privacy Policy for the purposes of:
(a) delivering the Services to you (including, maintaining and monitoring the proper operation of AppCapital Group App, fixing any problems in its operation, making our website more secure, to administer it, including troubleshooting, dealing with your enquiries, complaints and requests);
(b) ensuring and protecting the safety and security of AppCapital Group App, protecting our Intellectual Property Rights and other rights;
(c) conducting statistical and analytical surveys and researches, in particular for improving the Services and your user experience;
4.1.1. Personal data mentioned in Clause 2.2.2 shall be processed by Our Providers for the purposes of:
(a) attribution and tracking the performance of Our advertising campaigns and applications, including their effectiveness, usage, installations and downloads;
(b) targeted advertising, i.e. for showing the most relevant ads to users of the Devices across Internet network.
Please refer to the Privacy Policies of each Provider available at the respective web sites.
4.2. In case you voluntarily provide us with any additional personal data, we shall process these data solely for the purposes for which they were provided to us and for no longer they are needed to fulfil such purposes.
4.3. We limit access to data we hold about you to employees who we believe reasonably need to come into contact with that information to provide Services to you or in order to fulfil their official duties. These employees are bound by confidentiality obligations and may be subject to liability, if they fail to meet these obligations. We will take all steps reasonably necessary to ensure that your data are treated securely and in accordance with this Privacy Policy.
4.4. Information collected under Clause 2.2.2. will be used for automated decision making, as our Providers perform their advertising and analytics services based on automated analysis of your browsing behavior. As a consequence of automated decision making:
(a) You will receive advertisements throughout the Internet which the system considers the most relevant to you, and
(b) We may set certain preferences within your usage of AppCapital Group App (apply different prices, provide different content, etc.).
4.5. You can always limit collection of Your data used for targeting by managing your mobile devices

5. SHARING OF DATA
5.1. We cannot provide all Services by ourselves. We must, therefore, share collected information with third parties for the purposes as described in section 4 of this Policy. We also reserve the right to disclose your information (including personally identifiable information) when we are legally required to do so, to disclose your information in an anonymous and aggregated manner, meaning you could not be personally identified from it.
Your information may become available for the following categories of recipients:
(a) the companies being in the same corporate group with us;
(b) data storage, networking and security providers;
(c) advertising and analytics third party providers;
(d) providers assisting us with a client support;
(e) any other providers assisting us with delivering and improving the Services.
5.2. We may also share your data when it is required by law and/or any regulatory authority. In such circumstances, we will expressly inform the recipient of the confidential nature of the data shared.
5.3. Our third-party providers with whom we share your data or which directly collect such data via integration with AppCapital Group App may be located in non-EEA countries, where data protection and privacy regulations may be different from your home country and offer even lower level of protection. You acknowledge such transfer and processing of your data out of EEA to the countries where data protection and privacy regulations may be different from your home country and offer even lower level of protection. To safeguard your interests when transferring your personal data out of EEA, we will conclude with all out-of-EEA recipients standard data protection clauses adopted by the European Commission or our supervisory authority.
5.4. All third parties with which We share your data only get the minimum amount of data that are reasonably required in order for them to provide their service to us and therefore to you. The use of the shared information by such third parties is strictly limited to the purposes of processing outlined in Section 4 and is not permitted for any other purpose. All third parties with which we share your data are required to protect such data in accordance with all relevant laws and regulations and in a manner similar to the way we protect the same.
5.5. We will not share your data with third parties which are considered as not being able to provide its clients and potential client with the required level of protection.

6. YOUR RIGHTS
6.1. We respect the privacy rights of our users, and to the extent required by applicable law, will make reasonable commercial efforts to allow you to access, correct, object to the processing of, delete or port any of your personal data, provided that we are able to properly verify your identity and link it to any personal data in our possession. With respect to your personal data we process (if any) you have the right:
(a) to obtain from us the information regarding our processing of your personal data;
(b) to obtain from us without undue delay the rectification of inaccurate personal data concerning you;
(c) to obtain from us the erasure of your personal data (your ‘right to be forgotten’);
(d) to restrict our processing of your personal data, when it is permitted under applicable law;
(e) to object processing your personal data where we are processing your personal data: based on our legitimate interests (as set out above). If you ask us to stop processing your personal data on this bases, we will stop processing your personal data unless we can demonstrate compelling grounds as to why the processing should continue in accordance with data protection laws; and for direct marking purposes. If you ask us to stop processing your personal data on this bases, we will stop.
(f) to obtain from us your personal data in a structured, commonly used and machine-readable format and to transmit those data to another controller without any obstacle on our side;
(g) to withdraw your consent, where we are relying on consent to process your personal data;
(h) to lodge a complaint against us with a supervisory authority for GDPR purposes.
Please contact us via app@appcapital.vc to execute any of the rights as stated above.

7. PROTECTING CHILDREN’S PRIVACY
7.1. We do not knowingly collect or process personal data from or with respect to children under the age of 17, and you must be 17 years of age or older in order to use Services.
7.2. If you are a parent or legal guardian and believe that your child under the age of 17 has submitted his or her personal data or other data without your consent, permission, or authorization – please let us know immediately, and we will promptly act to remove your child’s data from our database, cease the use of such data and inform any other party we suspect to have access to such data to do the same.

8. PERIOD OF PROCESSING
8.1. Records of email, IP addresses and device ID are retained for as long as we need to deliver services to you unless we have a bases to further process your data as described in the Section 3 of this Policy.
8.2. If you request erasure of your data or you deleted our Apps from your device or you unsubscribed from our marketing communications we erase your data from our servers and request our providers to do the same within 30 days upon your request.
8.3. With respect to non-personal data We are not limited by any particular retention period.

9. PRIVACY POLICY UPDATES
9.1. We shall update this Privacy Policy from time to time. In the event we materially change this Privacy Policy including how We collect, process or use Your personal data, you will receive the respective notification via AppCapital Group App.
9.2. Any changes to this Privacy Policy with respect to processing of your personal data shall be subject to your prior consent, unless they are required under applicable law.
9.3. Unless otherwise required by law, any changes to this Privacy Policy with respect to processing of your non-personal data and changes with respect to processing of your personal data shall become effective immediately upon their posting in the App.
9.4. In case you continue to use AppCapital Group App after you have received the notification about the changes we presume that you have read the new Privacy Policy and accept all the introduced changes.
9.5. It is your responsibility to periodically review this Privacy Policy to be aware of the current changes (as we will notify you only about the material changes).
9.6. If you do not accept Privacy Policy following an amendment, do not start or continue to use AppCapital Group App.

10. QUESTIONS AND COMPLAINTS
10.1. If you have any requests concerning your personal information or any queries with regard to this Privacy Policy or if you consider that our collection, usage, disclosure and/or storage of your personal information violate any applicable data protection laws we are bound by, please feel free to contact us via app@appcapital.vc. We will consider your requests within reasonable time and provide you with an answer.
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