Privacy Policy

Introduction

AppTweak (hereafter: we, us or AppTweak) is committed to protecting and respecting your privacy.

This policy sets out the basis on which any information we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your information and how we will use it. By visiting our website www.apptweak.com you are accepting and agreeing to the practices described in this Privacy Policy.

Our Privacy Policy contains the following sections:

1. Information we collect from you
2. Cookies
3. Uses made of your information
4. Disclosure of your information
5. Transfer of your information
6. Your rights
7. Security of collected information
8. Retention of your information
9. External websites/apps
10. Agreement with collection and use of your information – changes to our Privacy Policy
11. Identity of data controller – contact details

Information we collect from you

We will collect and process the following information about you:

• Information you give us: This is information about you that you give us by filling in forms on www.apptweak.com (hereafter: our website) or by corresponding with us by phone, email or otherwise. The information you give us may include:
  • Your name, surname and email address
  • Your company name
  • Your billing informations
• Information we collect about you: during each of your visits to our website we will automatically collect the following information
  • technical information, including the Internet Protocol (IP) address used to connect your computer to the internet

Cookies

Cookies are used on this site (a cookie is a file dropped by our server on the hard drive of your computer. It keeps track of the visited site and contains a number of information items about this visit.). Our cookies are primarily designed to make the site work (technical session cookies). They aim at simplifying your visit and at improving the dialogue. You can decline the installation of the cookie on your computer by configuring your computer appropriately. Declining the cookie may however block access to some of the site’s services

Uses made of your information

We use the information we hold about you in the following ways:

• Information you give to us. We will use this information:
  • to improve our service and better serve you
  • to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;
  • to notify you about changes to our services;
• Information we collect about you. We will use this information:
  • to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve our website to ensure that content is presented in the most effective manner for you and for your computer/device;
  • as part of our efforts to keep our website safe and secure;
  • to measure or understand the effectiveness of advertising we deliver to you and others, and to deliver relevant advertising to you;

We may also process certain special categories of personal data where their processing is necessary for the establishment, exercise or defence of a legal claim.

We may also process your personal data:

• to carry out corporate restructuring operations;
• for internal and external audits;
• for the management of disputes with customers, suppliers and other data subjects.

The provision of your personal data may be necessary for:

• The performance of a contract to which you are a party (e.g. the contract the use of AppTweak’s ASO tool) or in order to take pre-contractual steps at your request (e.g. in the context of a request for information for the use of the Apptweak’s ASO tool);
• Compliance with a legal obligation applicable to us (e.g. with regard to invoicing, fraud detection, surveillance of our premises, taxation, etc.);
• The legitimate interests pursued by us (or by a data recipient) provided that these interests prevail over your fundamental rights and freedoms (e.g. the detection and the prevention of fraud and information security breaches, the conduct of corporate reorganisations, etc.).

In some cases, we will ask for your free, prior and informed consent before processing some of your personal data (e.g. photographs portraying you for company communication purposes, your email address for direct marketing purposes if you are not yet a client with us, etc.).

We do not subject you to decisions based exclusively on automated processing that produce legal effects concerning you or similarly significantly affect you.

The provision of some of your personal data (e.g. your name, address, etc.) is a condition to the conclusion with us of the contract for the use of AppTweak’s ASO tool.

The possible consequences of not providing your personal data could include our inability to meet our obligations under the contract or a breach by us of one or more obligations under applicable laws (e.g. accounting, tax or financial laws).

Recipients of your personal data

We may disclose your personal data to the following recipients:

• our affiliates (e.g. AppTweak Inc.);
• our business partners, including (e.g. software resellers);
• public authorities (including judicial and police authorities);
• banks and insurers;
• our professional advisors (e.g. financial advisors);
• our suppliers of IT related services, (e.g. data management advisor);
• providers of online payment services;

We will also disclose your information to third parties:

• in the event that we sell or buy any business or assets, in which case we may disclose your information to the prospective seller or buyer of such business or assets;
• if AppTweak or substantially all of its assets are acquired by a third party, in which case information held by it about its customers may be one of the transferred assets;
• if we are under a duty to disclose or share your information in order to comply with any legal obligation or to protect the rights, property, or safety of AppTweak, our customers, or others. This includes exchanging information with public authorities (including judicial and police authorities) in the event of, for example, a cyber security incident.

Transfer outside the European Economic Area

We may transfer your information to a destination outside the European Economic Area (the EEA).

In case your personal data is transferred to countries located outside of the EEA, we will ensure that appropriate safeguards are taken, such as:

• The country to which the personal data are transferred has benefited from an adequacy decision by the European Commission under Article 45 of the GDPR; or
• Standard data protection contractual clauses as approved by the European Commission pursuant to Article 47 of the GDPR have been established; or
• In case of a transfer of personal data to the United States, the transfer complies with the conditions imposed by the EU-US Privacy Shield under Article 45 of the GDPR.

For further information about transfers of personal data outside of the EEA, please consult the following link:

https://edps.europa.eu/data-protection/data-protection/reference-library/international-transfers_en

If you would like to obtain more information about the appropriate safeguards taken by AppTweak for the transfer of personal data outside of the EEA, please contact us by email at info@apptweak.com

Your rights

You have certain rights regarding the information we hold about you. These rights can be exercised by contacting us as set out below:

• You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we are providing you with the information in this privacy policy.
• you have the right to access the information we keep about you – this is because we want you to be aware of the information we have about you and to enable you to verify whether we process your information in accordance with the applicable data protection laws and regulations;
• you have the right, under certain circumstances, to block or suppress further use of your information. When the processing is restricted, we can still store your information, but we can no longer use it;
• if your information is inaccurate or incomplete, you have the right to request the rectification of your information;
• you have the right, under certain circumstances, to request the deletion or removal of your information from our systems;
• you have the right to lodge a complaint about the way we handle or process your information with your national data protection authority;
• if our processing of your personal information is based specifically on your consent, you have the right to withdraw that consent at any time. This includes your right to withdraw consent to our use of your information for direct marketing purposes;
• you have the right to obtain from us, under certain circumstances, your information in a structured, commonly used and machine readable form so you can reuse it for your own purposes across different services. For example: if you want to work with a different service provider, this enables you to move your information easily and in a secure manner to this new service provider.

You also have the right to object to certain types of processing, including processing for direct marketing purposes.

However, note that we may need to retain certain information, for example for legal or administrative purposes (e.g. keeping of accounting records).

For all requests set out above, please send us an email at info@apptweak.com with “data privacy request” in the subject line and include a copy of your identity card or another proof of your identity (e.g. driver’s license) to help us prevent unauthorised individuals from accessing, changing or deleting your information. We will respond to your request as soon as practically possible. If we need more than one month (from receipt of your request) to respond to your request, we will come back to you and let you know.

Security of collected information

We implement adequate technical and organizational measures to ensure a level of security of your personal data that is appropriate to the risks.

We take appropriate measures to ensure that we report security incidents leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data.

Should you discover or be made aware of any security and/or privacy related issues on AppTweak, please send us an email at security@apptweak.com and include details of the issue. We treat these emails with the highest priority and will reply as soon as possible.

Retention of your information

The information we hold about you will be retained in a manner consistent with the applicable data protection legislation. In any event, your information shall not be kept longer than is necessary to achieve the purposes stated in this Privacy Policy.

We use the following criteria to determine the retention periods of personal data according to the context and purposes of each processing operation:

• The date of the end of your commercial relationship with us;
• The sensitivity of personal data;
• Security reasons (for example, the security of our premises or of our information systems);
• Any current or potential dispute or litigation involving you;
• Any legal or regulatory obligation to retain or delete personal data (for example, a retention obligation imposed by accounting, tax or financial laws).

External websites

Our website may, from time to time, contain links to and from websites and/or applications of our partner networks, advertisers and affiliates. To the extent that hyperlinks or banner advertisements incorporating hyperlinks are utilized to access third party websites and/or applications, you should be aware that these third party websites and/or applications are not controlled by us and have their own privacy policies. Therefore, they are not subject to this Privacy Policy and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites and/or applications.

Agreement with collection and use of your information – changes to our Privacy Policy

By using this website, you acknowledge that you have read the terms of this Privacy Policy and that you agree with the collection and the use of your information as set out above.

We may amend this Privacy Policy from time to time. Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to the Privacy Policy. Your continued use of this website following the posting of changes to this Privacy Policy will indicate your acceptance of these changes. This Privacy Policy was most recently updated on February 19th 2020.

Right to object to marketing

If you are a client with us, we process your email address for direct marketing purposes.

You have the right to object at any time to the processing of your personal data for direct marketing purposes by unsubscribing from our mailing list or by sending us an email to info@apptweak.com

Identity of data controller – contact details

The data controller under this Privacy Policy is AppTweak SA, with company number 0839.873.510 and incorporated at Avenue Louise 235, 1050 Brussels (Belgium).

Questions, comments and requests regarding the Privacy Policy must be addressed to

• e-mail: info@apptweak.com
• Phone: +32 2 223 09 16
• Mail : Avenue Louise 235, 1050 Brussels (Belgium)