This Policy contains important information about who we are, how and why we collect, store, use, and share the information you give to us. It also explains your rights regarding our information collection practices and your choices about how we use the information we collect.

We, us, our – Apps Associates, LLC, Apps Associates (I) Pvt Ltd and Apps Associates GmbH.

Personal information – See “Personal information we collect from you” below.

Sensitive data – data consisting of racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, generic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation.

Services – offerings provided by our consultants available to customers.

Site – our website or websites of publicly accessible pages on the World Wide Web.

We regularly review our Privacy Policy and update its contents as needed. Updates will be posted on this web page as they are made.

This Policy was last updated on September 1, 2020.

We collect this personal information directly from you through the following methods:

• • Tradeshows and conferences.
  • Forms completed by website visitors.
  • Third party websites and search providers.
  • Website cookies.
  • Customer contact information.
  • Customer agreements and their associated addendums.
  • Vendor and subcontractor agreements and their associated addendums.

We may also collect personal information about you directly from third parties:

• In connection with providing Services pursuant to contracts with our corporate clients, we often obtain personal information of our client’s customers, employees and/or agents. This personal information varies based on the Services provided, but may include names, contact information, account numbers and other similar financial data. With respect to personal information that we receive from or on behalf of our clients in order to provide Services, our client remains the independent data controller and we act as a processor of such personal information.

We may use your information in the following ways:

• Marketing and sales purposes.
• Business and website analytics.
• To improve our products and services.
• To perform our contractual obligations to you where one exists.
• To prevent and detect fraud against you and us. We may use your IP address, the region or general location where your computer or device is accessing the internet, browser type, operating system and your use history of our website to help us design our site to better suit your needs and make the Site easier and more convenient to use.
• We may use your IP address to help diagnose problems with our server and to administer our website, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.

Our website does not track users when they cross to third-party websites, does not provide targeted advertising to them, and therefore does not respond to Do Not Track (DNT) signals. For more information on our Cookie Policy, see https://www.appsassociates.com/ad-and-cookie-policy/.

We do not use automated decision-making functions, including profiling.

Marketing/promotional use of your personal information:

• We do not share your information third parties with marketing partners for use in joint marketing campaigns, the creation of case studies, or to respond to questions.
• We may periodically send newsletters and promotional email about our services, or other information that we think you may find interesting, using the email address that you have provided. You can choose to be excluded from any future e-mail and promotional communications at any time or change your preferences by visiting our website at www.appsassociates.com.
• Personal information, non-personal information, and anonymous browsing may be used to gather broad demographic information used in marketing, promotion, analytics, or similar activities. This information may be aggregated to measure the number of visits, average time spent, page views and other statistics about users of a Site.

We only use, disclose, or otherwise process personal information when we have a lawful basis for doing so under applicable laws, including fulfilling our contractual obligations, complying with legal obligations, protecting the vital interests of a person, furthering our legitimate interests as a company, and for reasons to which you have consented.

We may also share personal information with the following categories of third parties:

Sub-contractors

Sub-contractors we have engaged in connection with providing Services to our clients.

• • Our professional advisers, including our attorneys and accountants.
  • Third parties to which we outsource certain services to assist with operating our business, such as IT managed service providers, document shredding services, software providers, information storage providers and other related service providers.
  • Third parties to which our clients have directed us to share information in connection with our Services, such as our clients’ attorneys and accountants.
  • Third-party service providers that assist us with client data analytics.
  • Third-party postal or courier providers that assist us with delivering marketing and other documents to you.

We may provide personal information to other service providers with which we contract, to process personal information for us at our direction (“Sub-Processors”). We conduct reasonably appropriate due diligence on our Sub-Processors and include in our contracts with our Sub-Processors provisions requiring them to keep the personal information confidential, to process the personal information in accordance with our instructions and for no other purpose, to only retain the data as long as it is necessary to meet their obligations, and to maintain reasonably appropriate information security systems.

We will only share information that we collect or receive regarding our users with third parties under the following circumstances:

• Consent : If we have a user’s consent to share any information, we may do so. We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please click on this link to submit a written request: https://www.appsassociates.com/privacy-request-form, dial this toll-free number: (844)203-9316, or send your request via email to [email protected].
• Agents : We may utilize other companies and individuals to perform functions on its behalf such as marketing new or additional services, sending postal and electronic mail to users, and hosting discussion forums. Such third parties have access to information needed to perform their functions but may not use it for other purposes.
• Aggregate Anonymous Information : We may provide to others the aggregate statistics about our users’ site activity for purposes of marketing, promotion, analytics, or similar activities. None of these statistics will identify users personally.
• Protection of Apps Associates or Others : We may disclose information about our users to others if we have a good faith belief that it is required or permitted to do so by law or legal process to respond to claims, to protect the rights, property or safety of us or others, or take action regarding illegal activities or suspected fraud, or in response to national security or law enforcement requests.
• Business Transfers : If we decide to sell all or part or our assets, we reserve the right to include information among the assets transferred to the acquiring company.
• Affiliates and Subsidiaries : We may share information among its affiliates and subsidiaries for the same purposes that we use the information.

Your personal data is stored on our servers, and on the servers of the cloud-based database management services we engage, located in the United States, while Office365 data is stored on Microsoft servers in Singapore.

We will keep your personal information while you have an account with us, or we are providing fulfilling a business obligation to you. Thereafter, we will keep your personal information for as long as is necessary:

• • To respond to any questions, complaints or claims made by you or on your behalf;
  • To show that we treated you fairly;
  • To keep records required by law.

Different retention periods apply for different types of personal information. The specific retention period will be defined in any agreements provided for the data collected. If a retention period is not specified, we will retain the data unless we receive a request for deletion. However, when it is no longer necessary to retain your personal information, we may delete it.

To exercise any of the above rights, click here: https://www.appsassociates.com/privacy-request-form, dial this toll-free number: (844)203-9316, or send your request via email to [email protected].

Our website is not directed toward children under 18 years of age. Apps Associates’ online privacy policy is to never to knowingly collect or maintain information about anyone under the age of 18. If you believe that we have mistakenly or unintentionally collected personal information of a minor through our sites without appropriate consent, please notify us by email at [email protected] so that we may take steps to delete it.

We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure we have put in place reasonable and appropriate security measures to safeguard and secure the information that we collect online.

In the event of a breach of the confidentiality or security of your personal information, we will notify you, as reasonably possible, and as reasonably necessary under applicable law so that you can take appropriate protective steps. We may notify you under such circumstances using the email address or addresses that we have on record for you. In all circumstances, you should also take care of how you handle and disclose your personal information.

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over the security or privacy of the information that you provide while you are visiting such sites. Any external sites are not governed by this Privacy Policy and you should exercise caution and review the privacy statement applicable to the website in question.

If you have any questions, complaints, or disputes regarding how we handle or protect your information, please bring it to our attention using one or more of the contact methods available in the “How to Contact Us” section of this document.

If you are a California resident or a European citizen, additional information is provided under “Your California Privacy Rights” and “Important information for residents of the European Union” below.

To exercise your rights relating to your Personal information or if you have any questions about our privacy practices, please contact us by email or telephone:

Email:[email protected]
Telephone number: (844)203-9316
Physical Address:Apps Associates, LLC
ATTN: Data Protection Officer
289 Great Road
Suite 308
Acton, MA 01720

We only use your information if we have a proper reason for doing so:

• To comply with our legal obligations.
• To perform our contractual obligations with you or to take steps at your request before entering a contract.
• For our legitimate interests or those of a third party. “Legitimate interests” means when we have a commercial reason to use your information to the extent it does not override your rights.
• Where you have given consent.

Your rights under the GDPR

The right to access – The right to be provided with a copy of your personal information.

The right to rectification – The right to require us to correct any mistakes in your personal information.

The right to erasure/right to be forgotten – The right to require us to delete your personal information—in certain situations.

The right to restrict processing – The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data

The right to data portability – The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

• Anytime to your personal information being processed for direct marketing (including profiling);
• In certain other situations, to our continued processing of your personal information.

Additional information regarding these rights can be found at: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/. To exercise any of the above rights, click here: https://www.appsassociates.com/privacy-request-form, dial this toll-free number: (844)203-9316, or send your request via email to [email protected].

Transferring personal data from the EU to a location outside the European Economic Area (“EEA”)

Our headquarters is in the United States. However, we have offices in the U.S.A., Europe and India. Information we collect from you will be processed in any of these three locations.

Information that you submit via the site may be transferred to countries outside the EEA. By way of example, this may happen if one or more of our servers are from, time to time, located in a country outside the EEA or one of our service providers is located in a country outside the EEA. If you make contact with any business featured on the site, your details may be transferred outside the EEA. If we transfer your information outside the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected.

Because non-EEA countries do not have the same data protection laws as the EEA, we ensure the transfer of your personal information is secure through use of the standard data protection contract clauses that have been approved by the European Commission. To obtain a copy of those clauses click here.

Enforcement and Dispute Resolution

If you have any questions, complaints, or disputes regarding how we handle or protect your information, please bring it to our attention by contacting our Data Protection Officer at [email protected]

You also have the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred. Information regarding your supervisory authority may be found at https://edpb.europa.eu/about-edpb/board/members_en. California law only requires businesses to respond to a customer request once during any calendar year.

Ad and Cookie Policy

We collect personal information about users over time and across different web sites when you use this site or service. We also have third parties that collect personal information this way. To do this, we use several common tracking tools. These may include browser cookies. We may also use web beacons, flash cookies, and similar technologies. Our vendors may also use these tools. In this policy “we” and “us” refers to both Apps Associates and our vendor

We use tracking tools, including cookies, on our websites. Cookies are small files of letters and numbers that may be stored by your browser on your equipment when you access websites. We may use cookies to distinguish you from other users of the Site. Third parties also use cookies on our sites. We may use the following types of cookies:

• Strictly necessary cookies, which are required for the operation of a Site. They include, for example, cookies which enable users to log on to secure areas of a Site, use a shopping cart, or access and participate in discussion forums on a Site.
• Analytical or performance cookies, which allow providers to recognize and count the number of users and to see how users move around a Site when they are using it. This helps us to improve the way the Sites work, for example, by ensuring that users can more easily find what they are looking for.
• Functionality cookies, which are used to recognize users when they return to a Site. They enable users to store preferences for certain types of information so that they do not have to input those preferences every time they use a Site.
• Targeting cookies, which record a user’s visit to a website, the individual pages visited and the links followed. If the cookie is set by a third party (for example, a third-party advertising partner) which also monitors traffic on other websites, this type of cookie may also be used to track a user’s movements across different websites and to create profiles of their general online behavior. We do not currently use cookies to deliver targeted advertisements to you when you are on a Site or third-party websites.

To learn more, visit here or here. These pages also explain how you can manage and delete cookies. We use tracking tools:

• To recognize new visitors to our web sites.
• To recognize past customers.
• To improve our website and better understand your visits on our platforms.
• To integrate with third party social media websites.
• To serve you with interest-based or targeted advertising (see below for more on interest-based advertising).
• To observe your behaviors and browsing activities over time across multiple websites or other platforms.
• To better understand the interests of our customers and our website visitors.

We request your consent to the use of cookies when you first visit a Site. You can choose to accept or decline cookies when you first visit a Site by clicking on the Agree & Dismiss button when you enter the site.

We and our partners display interest-based advertising using information gathered about you over time across multiple websites or other platforms.

Interest-based advertising or “online behavioral advertising” includes ads served to you after you leave our website, encouraging you to return. They also include ads we think are relevant based on your browsing habits or online activities. These ads might be served on websites or on apps. They might also be served in emails. We might serve these ads, or third parties may serve ads. They might be about our products or other companies’ products.

To decide what is relevant to you, we use information you make available to us when you interact with us, our affiliates, and other third parties. We gather this information using the tracking tools described above. For example, we or our partners might look at your registrations or browsing behaviors. We might look at these activities on our platforms or the platforms of others. We work with third parties who help gather this information.

Your browser may give you the ability to control cookies. How you do so will depend on the type of cookie. Certain browsers can be set to reject browser cookies. To find out more about how to enable, disable, or delete cookies from your web browser, please visit here and here. To control flash cookies, which we may use on certain websites from time to time, you can go here. Why? Because flash cookies cannot be controlled through your browser settings.

Our Do Not Track Policy: Some browsers have a “Do Not Track” feature that allows you to tell a web site not to track you. These features are not all uniform. We do not currently respond to those signals. If you block cookies, certain functionality on our sites may not work. If you block or reject cookies, not all of the tracking described here will stop. Certain options you select are browser and device specific.

The Self-Regulatory Program for Online Behavioral Advertising provides consumers with the ability to opt-out of having their online behavior recorded and used for advertising purposes. To opt out of having your online behavior collected for advertising purposes, visit www.aboutads.info/choices.

Some of the tracking technologies we may use do not participate in the Self-Regulatory Program for Online Behavioral Advertising. This means you will not be opted out by following the instructions above. Instead, click on the link to get more information about how to opt-out of that tracker’s cookies. Certain choices you make are both browser and device specific.

Here is more information about the tracking technologies and cookies we currently use on www.appsassociates.com. We use all of these tracking technologies to improve our site and the experience of our visitors:

• DoubleClick: DoubleClick allows us to capture and report on the actions of users who visit our website after viewing or clicking on one of our paid ads. This allows us to determine the effectiveness of our online campaigns in terms of both sales and user activity on our sites.
• Facebook Connect: We use this technology to allow users to share their experiences with our websites on Facebook and to track visitors to our sites who have interacted with our ads or posts on Facebook. For example, we may collect your browser information, demographic data, and interaction data. This allows us to determine the effectiveness of our marketing efforts on Facebook.
• Google AdWords Conversion : We use conversion tracking to help us understand how effective our digital campaigns are.
• Google Analytics: We use Google Analytics to collect information about how visitors use our website. For example, we collect details of the site where the visitor has come from and the total number of times a visitor has been to our website. This allows us to determine the effectiveness of our online campaigns in terms of sales and user activity on our sites.
• Google Dynamic Remarketing : We use these tracking tools to track user behavior over time and across third party sites to improve the effectiveness of our online advertising. We collect information about what ads users view and whether they click on the ads. We use this information to improve and customize our advertising.
• Google Tag Manager: We use Google Tag Manager to measure what features on our site are interesting to our users. It also helps us understand what portions of our site users clicked on during a certain time and how users arrived on our site. This allows us to determine the effectiveness of our online campaigns in terms of sales and user activity on our sites.
• Twitter : Twitter is an online social networking service that enables users to send and read short messages. We use the Twitter cookies to enable social sharing buttons on our sites, as well as to track social media and other web browsing behavior in order to target ads and promotions to your interests. For more information on how to opt-out of Twitter cookies, you can go here.
• Pardot : We use this tool to track users that have interacted with our email communications and visited our website. We may use this information to improve our emails and customize user experiences. We also use information collected through this tool to determine the effectiveness of our online campaigns in terms of sales and user activity on our sites.
• LinkedIn : We use LinkedIn cookies to enable social sharing buttons on our sites, as well as to track social media and other web browsing behavior in order to target ads and promotions to your interests.
• Drift : Drift is an online conversational tool that we use to answer questions in real time, route qualified leads to the right sales reps, and start conversations with prospects in real time.

Effective Date 12/27/2019

Last Updated 12/27/2019

The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to California consumers. The CCPA applies only to California consumers and is effective on January 1, 2020. If you are not a California consumer, this Notice does not apply to you and you should not reply upon it.

Pursuant to the CCPA, we are required to disclose to California consumers, upon request, the identity of any third parties to whom the business has disclosed personal information within the previous calendar year, along with the type of personal information disclosed, for the third parties’ direct marketing purposes. Those rights include:

• The right to know which personal information is being collected.
• The right to know if personal data is being sold or shared, and to whom.
• The right to object to the sale of personal data.
• The right to access one’s own personal information.
• The right to equal service and price, even for consumers who exercise their privacy rights.

Upon receipt of a valid request through our online form https://www.appsassociates.com/privacy-request-form or received by phone at (844)203-9316, we will comply with your request in accordance with the CCPA and the Apps Associates Privacy Policy.

You may request this information up to 2 times in a 12-month period. Each request is applicable for the 12 months preceding our receipt of a valid request. We must also be able to verify your identity for us to execute your rights request.

The types of information you may request include:

• Specific personal information collected.
• Our business purpose for collecting your personal information.
• The categories of personal information collected.
• The categories of sources of the personal information collected.

We do not share, disclose or sell your personal information to third parties. However, if we are deemed to have shared, disclosed or sold your personal information as defined by the CCPA, we will provide the categories of personal information shared, disclosed or sold to the third party.

California residents may opt-out of the “sale” of your personal information, which is defined as the sale of information for “valuable consideration.” If you are a California resident and would like to opt out, you may do so as designated on the following page: https://www.appsassociates.com/privacy-request-form.

Under the CCPA, you have the right to request that we delete your personal information. In order to for us to delete your personal information we must receive a valid request from you an authorized agent as defined by the CCPA.

A valid delete request can be initiated by completing this form https://www.appsassociates.com/privacy-request-form. You can also receive assistance with deletion requests by calling (844)203-9316. We must be able to verify your identity for us to execute your deletion request.

We may deny a deletion request if it is not valid or for any of these exceptions:

• To complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’s ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
• To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
• To debug in order to identify and repair errors that impair existing intended functionality.
• To exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
• To comply with the California Electronic Communications Privacy Act.
• To engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
• To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.
• To comply with a legal obligation.
• To otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

We do not share, disclose or sell your personal information to third parties. However, if we are deemed to have shared, disclosed or sold your personal information as defined by the CCPA, we will provide the categories of personal information shared, disclosed or sold to the third party.

You may also make a data portability request of your personal information. If you make such a request, we will provide your data in a generally accepted format that can be readily accessed by the recipient.

CCPA Web Form: https://www.appsassociates.com/privacy-request-form
Phone: (844)203-9316
Email: [email protected]

All personal information requests will be processed in accordance with the CCPA specifications and timeframes as defined at the time of the request or as otherwise required by applicable law. Communications to you regarding personal information requests will be made electronically through our online request system or by regular postal mail.

Apps Associates reserves the right to amend the California Privacy Rights Notice at our discretion at any time. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes. Please refer to the last update notice of this section for the date of the last amendment to this notice.