commitment to protecting our users’ privacy. The terms “AppGrowth,” “we,” “us”, and “our”
include AppGrowth Inc. and any affiliates and subsidiaries. The terms “you” and “your” refer to
any individuals and entities who use our Services or visit our website (the “Website”) (including
our publishers, developers, advertisers, demand partners, and other service providers) and our
1.2 This Policy describes our online and offline information practices, the kinds of
information we may collect, how we intend to use that information, with whom your information
may be shared, and how you can opt-out of such uses or correct or change such information. By
using our Services or our Website, you agree to the practices described in this Policy.
This Policy applies to any information relating to an identified or identifiable natural person
(“Personal Information”) that is collected, recorded, stored, adapted, used, or otherwise made
available (collectively, “Processed”) by AppGrowth in the course of our business providing a
demand-side platform for real-time bidding exchanges, tools and other services (the “Services”)
or the functionality of the Website. All individuals and entities whose responsibilities include
Processing Personal Information on our behalf are expected to protect that data by adherence to
3. TRANSPARENCY/NOTICE: TYPES OF PERSONAL INFORMATION WE
COLLECT AND HOW WE USE IT
3.1 The types of Personal Information we may collect (directly from you or from thirdparty
sources) and our privacy practices depend on the nature of the relationship you have with
AppGrowth and the requirements of applicable law. AppGrowth may collect Personal Information
in the following ways:
• You may provide Personal Information directly to AppGrowth through interacting with
the Services or our Website, participating in surveys, during events, and requesting
products, Services, or information.
• As you interact with the Services or our Website, certain passive information may also
be collected about your visit, including through Technologies as described below. We
endeavor to collect only that information which is relevant for the purposes of
Processing. Below are the ways we collect Personal Information and how we use it.
3.2 Types of Personal Information AppGrowth Collects
AppGrowth collects Personal Information regarding its current, prospective, and former clients,
customers, publishers, demand partners, users, visitors, guests, and Employees (collectively
• Information You Provide Directly to Us. When you use the Services or the Website or
engage in certain activities, such as registering for an account with AppGrowth,
requesting Services or information, or contacting us directly, we may ask you to provide
some or all of the following types of information:
o Account Registration. When you register for an account to access our
Services, we collect information about you which may include your name,
address, telephone number, email address, and billing information such as your
credit card number.
o Communications with Us. We may also collect Personal Information from you
such as your name, email address, phone number or mailing address when you
choose to request information about our Services, register for a newsletter,
contact customer service, or otherwise communicate with us.
o Surveys. From time to time, we may contact you to participate in online
surveys. If you do decide to participate, you may be asked to provide certain
information which may include Personal Information. All information
collected from your participation in our surveys is provided by you voluntarily.
We may use such information to improve our Website and/or Services and in
any manner consistent with the policies provided herein.
• Automatic Data Collection. We may collect certain information automatically through
our Services, Website, or other methods of web analysis, such as your Internet protocol
(IP) address, cookie identifiers, mobile advertising identifiers, and other device
identifiers that are automatically assigned to your Device when you access the Internet,
location data, browser type, operating system, Internet service provider, pages that you
visit before and after using the Website or our Services, the date and time of your visit,
the amount of time you spend on each page, information about the links you click and
pages you view on our Website, and other actions taken through use of the Website or
Services such as preferences.
• Information from Other Sources. We may also obtain information about you through
third-party services and organizations to supplement information provided by you. This
supplemental information allows us to verify information that you have provided to
AppGrowth and to enhance our ability to provide you with information about our
business and Services.
3.3 Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based
We, as well as third parties that provide content, advertising, or other functionality on our Services
technologies (“Technologies”) to automatically collect information through the Services or
Website. We use Technologies that are essentially small data files placed on your computer, tablet,
mobile phone, or other devices (referred to collectively as a “Device”) that allow us to record
certain pieces of information whenever you visit or interact with our Website or Services, and to
recognize you across Devices.
• Cookies. Cookies are bits of data stored on your Device through your browser or mobile
application that allow the mobile application to remember you the next time you visit.
Cookies enable smoother, more efficient use of the Website by storing your specific
information and preferences such as theme, language setting, privacy preferences, and
even user ID and password, so you do not need to reenter those each time you visit the
Website. You may choose to block or delete cookies if your browser permits, but doing
so may affect your use of the Website and your ability to access certain features of the
• Advertising Identifiers. We may also use mobile advertising identifiers to recognize
your device and perform the services. Depending on your device, you can chose to
change or limit the transmission of your mobile advertising identifier by going into
your device settings.
• Web Bugs/Pixel Tags/Web Beacons. A web bug (also known as a pixel tag or web
beacon) is a piece of code embedded on the Site that collects information about users’
engagement on that web page. We may also use web bugs to help us understand the
behavior of our users by allowing us to track user demographics and traffic patterns.
• Social Media Widgets. Our Website includes social media features such as the Facebook
“Like” button and LinkedIn (that might include widgets such as the share this button
or other interactive mini-programs). These features may collect information including
your IP address and which page you are visiting on our Website, and may set a cookie
to enable the feature to function properly. These social media features are either hosted
by a third party or hosted directly on our Website. Your interactions with these features
• Analytics. We may also utilize Google Analytics and Yandex Metrics in the collection,
compilation and analysis of information regarding visitor behavior and visitor
demographics on some of our Services, and to develop website content. This analytics
data is not tied to any Personal Information. For more information about Google
Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of
Google’s collection and Processing of data generated by your use of the Services by
going to http://tools.google.com/dlpage/gaoptout. You can out opt of Yandex Metrics
by going to https://yandex.com/support/metrica/general/opt-out.xml
Our uses of such Technologies fall into the following general categories:
• Operationally Necessary. We may use Technologies that are necessary to the operation
of our Services or Website. This includes Technologies that allow you access to our
Services; or that are required to identify irregular Website behavior, prevent fraudulent
activity and improve security;
• Performance Related. We may use Technologies to assess the performance of our
Services or Website, including as part of our analytics practices, to help us understand
how our visitors use our Website, determine if you have interacted with our messaging,
determine whether you have viewed an item or link, or to improve our Services or
• Functionality Related. We may use Technologies that allow us to offer you enhanced
functionality when accessing or using our Services or Website. This may include
identifying you when you sign into our Website or keeping track of your specified
preferences, interests, or past items viewed so that we may enhance the presentation of
content on our Website;
• Advertising or Targeting Related. We may use first-party or third-party Technologies
to deliver content, including ads that may be relevant to your interests, on our Website
or on third-party websites. This includes using Technologies to understand the
usefulness to you of the advertisements and content that have been delivered to you,
such as whether you have clicked on an advertisement.
We may also combine the information we collect through Technologies with other Personal
Information we have collected from and about you. If you would like to opt out of the Technologies
we employ through our Services, you may do so by blocking, deleting, or disabling them as your
browser or Device permits.
3.4 How AppGrowth Uses Your Information
We acquire, hold, use, and Process Personal Information based on the legal grounds and for the
legitimate business purposes outlined in this Policy, such as:
• To Provide Services or Information Requested: AppGrowth may use information
about you to fulfill requests for Services or information, including information about
potential or future Services, including to:
o Generally manage Individual information and accounts;
o Respond to questions, comments, and other requests;
o Provide access to certain areas, functionalities, and features of AppGrowth’s
Services or Website;
o Allow you to register for events.
• Administrative Purposes: AppGrowth may use Personal Information about you for its
administrative purposes, including to:
o Ensure you have a personalized and consistent experience in using the Website
o Protect the security of our Services and Website and to prevent fraud;
o Measure interest in AppGrowth’s Services and perform analytics;
o Notify you of changes to the Website or Services;
o Develop new Services;
o Ensure internal quality control;
o Verify Individual identity;
o Communicate about Individual accounts and activities on AppGrowth’s
Services, Website and systems, and, in AppGrowth’s discretion, changes to
any AppGrowth policy;
o Send email to the email address you provide to us to verify your account and
for informational and operational purposes, such as account management,
customer service, or system maintenance;
o Process payment for Services purchased;
o Process applications and transactions;
o Prevent potentially prohibited or illegal activities;
• Marketing AppGrowth Services: AppGrowth may use Personal Information to provide
you with materials about offers, products, and Services that may be of interest,
including new content or Services. AppGrowth may provide you with these materials
by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses
o To tailor content, advertisements, and offers;
o To notify you about offers, products, and services that may be of interest to
o To provide Services to you and our sponsors;
o For other purposes disclosed at the time that Individuals provide Personal
o Otherwise with your consent.
You may contact us at any time to opt-out of the use of your Personal Information for marketing
purposes, as further described in Section 6 below.
• Research and Development: AppGrowth may use Personal Information to create nonidentifiable
information that we may use alone or in the aggregate with information
obtained from other sources, in order to help us improve our Website, to optimally
deliver our existing Services or develop new Services. From time to time, AppGrowth
may perform research (online and offline) via surveys. We may engage third-party
service providers to conduct such surveys on our behalf. All survey responses are
voluntary, and the information collected will be used for research and reporting
purposes to help us better serve Individuals by learning more about their needs and the
quality of the Services we provide. The survey responses may be utilized to determine
the effectiveness of our Services or our Website, various types of communications,
advertising campaigns, and/or promotional activities. If an Individual participates in a
survey, the information given will be used along with that of other study participants.
We may share anonymous Individual and aggregate data for research and analysis
• Direct Mail, Email and Outbound Telemarketing: Individuals who provide us with
Personal Information, or whose Personal Information we obtain from third parties, may
receive periodic emails, newsletters, mailings, or phone calls from us with information
on AppGrowth’s or our business partners’ products and services or upcoming special
offers/events we believe may be of interest. We offer the option to decline these
communications at no cost to the Individual by following the instructions in Section 6
• Mobile Devices: AppGrowth provides Services that are specifically designed to be
compatible and used on mobile Devices. AppGrowth will collect certain information
that your mobile Device sends when you use such Services, like a GPS location, user
settings and the operating system of your Device. AppGrowth’s Services require that
users log in with an account, and information collected through mobile versions of the
Services is associated with user accounts. In addition, AppGrowth may enable
Individuals to download an application, widget, or other tool that can be used on
Devices. Some of these tools may store information on Devices. These tools may
transmit Personal Information to AppGrowth to enable Individuals to access user
accounts and to enable AppGrowth to track use of these tools. Some of these tools may
enable users to email reports and other information from the tool. AppGrowth may use
personal or non-identifiable information transmitted to AppGrowth to enhance these
tools, to develop new tools, for quality improvement and as otherwise described in this
Policy or in other notices AppGrowth provides.
• Anonymous and Aggregated Information: AppGrowth may use Personal Information
and other information about you to create anonymized and aggregated information,
such as de-identified demographic information, de-identified location information,
information about the Device from which you access AppGrowth’s Services or
Website, or other analyses we create. Anonymized and aggregated information is used
for a variety of functions, including the measurement of visitors’ interest in and use of
various portions or features of the Services or Website. Anonymized or aggregated
information is not Personal Information, and AppGrowth may use such information in
a number of ways, including research, internal analysis, analytics, and any other legally
permissible purposes. We may share this information within AppGrowth and with third
parties for our or their purposes in an anonymized or aggregated form that is designed
to prevent anyone from identifying you.
• Sharing Content with Friends or Colleagues: AppGrowth’s Services may offer various
tools and functionality. For example, AppGrowth may provide functionality on its
Services that will allow you to forward or share certain content with a friend or
colleague. Email addresses that you may provide for a friend or colleague will be used
to send your friend or colleague the content or link you request, but will not be collected
or otherwise used by AppGrowth or any other third parties for any other purpose.
• Other Uses: AppGrowth may use Personal Information for other purposes for which we
have a legitimate interest, such as direct marketing, individual or market research, antifraud
protection, or any other purpose disclosed to you at the time you provide Personal
Information or with your consent.
3.5 Third-Party Websites and Social Media Platforms
The Website may contain links to other websites and other websites may reference or link to our
Website or other Services. These other domains and websites are not controlled by us, and
AppGrowth does not endorse or make any representations about third-party websites or social
media platforms. We encourage our users to read the privacy policies of each and every website
and application that they interact with. We do not endorse, screen or approve, and are not
responsible for the privacy practices or content of such other websites or applications. Visiting
these other websites or applications is at your own risk.
The Website and our Services may also contain links and interactive features with various social
media platforms. If you already use these platforms, their cookies may be set on your Device when
using our Website or Services. You should be aware that Personal Information which you
voluntarily include and transmit online in a publicly accessible blog, chat room, social media
platform or otherwise online, or that you share in an open forum may be viewed and used by others
without any restrictions. We are unable to control such uses of your information when interacting
with a social media platform, and by using such services you assume the risk that the Personal
Information provided by you may be viewed and used by third parties for any number of purposes.
3.6 Software Development Kit
To provide our Services, we offer a software development kit (“SDK”). If you are a developer or
publisher using our SDK through your mobile application, we may collect Personal Information
about users of your mobile application through our SDK, including IP addresses, mobile
advertising IDs, GPS location (if appropriate permission is given), carrier, language settings,
application usage statistics such as launch times and duration, ad views and click-throughs.
Advertisers or demand partners that provide content through our SDK may also collect Personal
Information or other information about your users through our SDK. You agree that, in order to
use our SDK, you will obtain appropriate consent from your users for the collection, use and
sharing of Personal Information through our SDK, and that you will maintain and process all user
mobile application is distributed or used and users are located.
If you use our SDK, you agree that we may also share certain non-personal information about your
use of the SDK through your mobile application with advertisers and demand partners who provide
content through our SDK. Such information may include the number of requests you receive for
ad placements on your Mobile Properties, the number of impressions and click-throughs generated,
information about revenue you receive, and eCPM data.
4. HUMAN RESOURCES DATA
AppGrowth collects Personal Information from Employees, their contact points in case of a
medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”).
“Employees” include current, temporary, permanent, prospective or former employees, directors,
contractors, workers, or retirees of AppGrowth. The Human Resources Data we collect may
include title, name, address, phone number, email address, date of birth, passport number, driver’s
license number, Social Security number or other government-issued identification number,
financial information related to credit checks, bank details for payroll, information that may be
recorded on a CV or application form, language abilities, contact information of third parties in
case of an emergency and beneficiaries under any insurance policy. We may also collect sensitive
Human Resources Data such as details of health and disability, including mental health, medical
leave, and maternity leave; and information about national origin or immigration status.
We acquire, hold, use and Process Human Resources-related Personal Information for a variety of
business purposes including:
• Workflow management, including assigning, managing and administering projects;
• Human Resources administration and communication;
• Payroll and the provision of benefits;
• Compensation, including bonuses and long-term incentive administration, stock plan
administration, compensation analysis, including monitoring overtime and compliance
with labor laws, and company recognition programs;
• Job grading activities;
• Performance and employee development management;
• Organizational development and succession planning;
• Benefits and personnel administration;
• Absence management;
• Helpdesk and IT support services;
• Regulatory compliance;
• Internal and/or external or governmental compliance investigations;
• Internal or external audits;
• Litigation evaluation, prosecution, and defense;
• Diversity and inclusion initiatives;
• Restructuring and relocation;
• Emergency contacts and services;
• Employee safety;
• Compliance with statutory requirements;
• Processing of Employee expenses and travel charges;
• Acquisitions, divestitures, and integrations.
5. ONWARD TRANSFER—APPGROWTH MAY DISCLOSE YOUR
5.1 Information We Share
We may share your information as described in this Policy (e.g., with our third-party service
providers; to comply with legal obligations; to protect and defend our rights and property) or with
• We Use Vendors and Service Providers. We may share any information we receive
with vendors and service providers, including advertisers that provide content through
our SDK. The types of service providers (processors) to whom we entrust Personal
Information include service providers for: (i) provision of IT and related services, such
as web hosting or data management; (ii) provision of information and services you have
requested; (iii) payment processing; (iv) customer service activities; and (v) in
connection with the provision of the Website. AppGrowth has executed appropriate
contracts with the service providers that prohibit them from using or sharing Personal
Information except as necessary to perform the contracted services on our behalf or to
comply with applicable legal requirements.
• Business Partners. We may choose to share Personal Information with our business
partners and affiliates for our and our affiliates’ internal business purposes, or to
provide you with Services that you have requested. AppGrowth may also provide
Personal Information to business partners with whom we may jointly offer products or
services, or whose products or services we believe may be of interest to you. In such
cases, our business partner’s name will appear, along with AppGrowth’s. AppGrowth
requires our affiliates and business partners to agree in writing to maintain the
confidentiality and security of Personal Information they maintain on our behalf and
not to use it for any purpose other than the purpose for which AppGrowth provided it
• Interest-Based Advertising and Third Party Marketing. Through our Services,
AppGrowth may allow third-party advertising partners to set tracking tools (e.g.,
cookies or other Technologies) to collect information regarding your activities (e.g.,
your IP address, page(s) visited, time of day). We may also share such de-identified
information as well as selected Personal Information (such as demographic information
and past purchase history) we have collected with third-party advertising partners.
These advertising partners may use this information (and similar information collected
from other websites) for purposes of delivering targeted advertisements to you when
you visit non-AppGrowth related websites within their networks. This practice is
commonly referred to as “interest-based advertising” or “online behavioral advertising.
We may allow access to other data collected by the Website to facilitate transmittal of
information that may be useful, relevant, valuable or otherwise of interest to you. If
you prefer that we do not share your Personal Information with third-party advertising
partners, you may opt-out of such sharing at no cost by following the instructions in
Section 6 below.
• Disclosures to Protect Us or Others (e.g., As Required by Law and Similar
Disclosures). We may access, preserve, and disclose your Personal Information, other
account information, and content if we believe doing so is required or appropriate to:
(i) comply with law enforcement or national security requests and legal process, such
as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or
others’ rights, property, or safety; (iv) to enforce AppGrowth policies or contracts; (v)
to collect amounts owed to AppGrowth; (vi) when we believe disclosure is necessary
or appropriate to prevent physical harm or financial loss or in connection with an
investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good
faith, believe that disclosure is otherwise necessary or advisable.
In addition, from time to time, server logs may be reviewed for security purposes—
e.g., to detect unauthorized activity on the Services. In such cases, server log data
containing IP addresses may be shared with law enforcement bodies in order that they
may identify users in connection with their investigation of the unauthorized activities.
• Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition,
financing due diligence, reorganization, bankruptcy, receivership, sale of company
assets, or transition of service to another provider, then your information may be sold
or transferred as part of such a transaction as permitted by law and/or contract. Should
such an event occur, AppGrowth will endeavor to direct the transferee to use Personal
Information in a manner that is consistent with the Policy in effect at the time such
Personal Information was collected.
5.2 Data Transfers
All Personal Information collected via or by AppGrowth may be stored anywhere in the world,
including but not limited to, in the United States, in the cloud, on our servers, on the servers of our
affiliates or the servers of our service providers. Your Personal Information may be accessible to
law enforcement or other authorities pursuant to a lawful request. By providing information to
AppGrowth, you consent to the storage of your Personal Information in these locations.
6. CHOICE/MODALITIES TO OPT-OUT
You have the right to opt out of certain uses and disclosures of your Personal Information. Where
you have consented to AppGrowth’s Processing of your Personal Information or sensitive Personal
Information, you may withdraw that consent at any time and opt-out to further Processing by
following the instructions in this Section. Even if you opt-out, we may still collect and use non-
Personal Information regarding your activities on our Website and/or information from the
advertisements on third-party websites for non-interest based advertising purposes, such as to
determine the effectiveness of the advertisements.
6.2 Email and Telephone Communications
If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom
of the email to opt-out of receiving future emails. We will process your request within a reasonable
time after receipt. Note that you will continue to receive transaction-related emails regarding
products or services you have requested. We may also send you certain non-promotional
communications regarding AppGrowth and our Services and you will not be able to opt out of
those communications (e.g., communications regarding updates to our Terms or this Policy).
We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process
requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after
receipt, or such shorter time as may be required by law.
6.3 Human Resources Data
With regard to Personal Information that AppGrowth receives in connection with the employment
relationship, AppGrowth will use such Personal Information only for employment-related
purposes as more fully described above. If AppGrowth intends to use this Personal Information
for any other purpose, AppGrowth will notify the Individual and provide an opportunity to opt-out
of such uses.
6.4 Do Not Track
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is
a way for users to inform websites and services that they do not want certain information about
their webpage visits collected over time and across websites or online services. Please note that
we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
6.5 Cookies and Interest-Based Advertising
We hope that you find the display of interst-based Ads valuable. However, if you wish to opt-out
of these advertising services, you can edit your preferences by visiting the “Settings” page of the
Website and selecting the option to opt-out.
As noted above, you may stop or restrict the placement of cookies on your Devices or remove
them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile Devices, application users may opt out of certain mobile ads via their Device settings or by downloading the
AppChoices mobile application offered by the Digital Advertising Alliance.
The online advertising industry also provides websites from which you may opt-out of receiving
targeted ads from our data partners and our other advertising partners that participate in selfregulatory
programs. You can access these, and also learn more about targeted advertising and
consumer choice and privacy, at networkadvertising.org/managing/opt_out.asp, or
www.youronlinechoices.eu and www.aboutads.info/choices/. You can also choose not to be
included in Google Analytics by following this link: tools.google.com/dlpage/gaoptout
To be clear, whether you are using our opt-out and/or an online industry opt-out, these cookiebased
opt-outs must be performed on each Device and browser that you wish to have opted-out.
For example, if you have opted-out on your computer browser, that opt-out will not be effective
on your mobile Device. You must separately opt-out on each Device. Advertisements on thirdparty
directed to you based on anonymous, non-Personal Information collected by advertising partners
over time and across websites. These advertisements provide a mechanism to opt-out of the
advertising partners’ use of this information for interest-based advertising purposes.
7. SECURITY OF YOUR INFORMATION
The security of your Personal Information is important to us. We maintain appropriate safeguards
and current security standards to protect your Personal Information from unauthorized access,
disclosure, or misuse. However, no system can be completely secure, and we cannot ensure or
warrant the security of any information you provide to us. While we take meaningful steps to
secure your information, we do not promise, and you should not expect, that your Personal
Information will always remain secure. We do not accept liability for unintentional disclosure.
By using the Website or providing Personal Information to us, you agree that we may communicate
with you electronically regarding security, privacy, and administrative issues relating to your use
of the Website. If we learn of a security system’s breach, we may attempt to notify you
electronically by posting a notice on the Website or sending an e-mail to you. You may have a
legal right to receive this notice in writing.
8. RIGHTS OF ACCESS, RECTIFICATION, ERASURE, AND RESTRICTION
You can review and change certain Personal Information related to your use of our Website or
Services (such as your name and contact information). To access your information, simply sign in
to your account and you will be able to edit your Personal Information.
You may inquire as to whether AppGrowth is Processing Personal Information about you, request
access to Personal Information, and ask that we correct, amend or delete your Personal Information
where it is inaccurate. Where otherwise permitted by applicable law, you may send an e-mail to
firstname.lastname@example.org or use any of the methods set out in this Policy to request access to, receive
(port), restrict Processing, seek rectification, or request erasure of Personal Information held about
you by AppGrowth. Such requests will be processed in line with local laws.
Although AppGrowth makes good faith efforts to provide Individuals with access to their Personal
Information, there may be circumstances in which AppGrowth is unable to provide access,
including but not limited to: where the information contains legal privilege, would compromise
others’ privacy or other legitimate rights, where the burden or expense of providing access would
be disproportionate to the risks to the Individual’s privacy in the case in question or where it is
commercially proprietary. If AppGrowth determines that access should be restricted in any
particular instance, we will provide you with an explanation of why that determination has been
made and a contact point for any further inquiries. To protect your privacy, AppGrowth will take
commercially reasonable steps to verify your identity before granting access to or making any
changes to your Personal Information.
AppGrowth retains the Personal Information we receive as described in this Policy for as long as
you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide
our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business
purposes, enforce our agreements, and comply with applicable laws.
10. CHILDREN’S PRIVACY
The Website is restricted to individuals over the age of 18. We do not knowingly collect, maintain,
or use Personal Information from children under 13 (and in certain jurisdictions under the age of
16) years of age, and no part of the Website is directed to children under the age of 13 (and in
certain jurisdictions under the age of 16). If you learn that your child has provided us with Personal
Information without your consent, you may alert us at email@example.com. If we learn that we
have collected any Personal Information from children under 13 (and in certain jurisdictions under
the age of 16), we will promptly take steps to delete such information and terminate the child’s
11. INTERNATIONAL USERS
By using the Website, you will transfer data to the United States. By choosing to utilize the
Services or otherwise provide information to us, you agree that any dispute over privacy or the
United States of America.
If you are visiting from the European Union or other regions with laws governing data collection
and use, please note that you are agreeing to the transfer of your information to the United States
and processing globally. By providing your Personal Information, you consent to any transfer and
processing in accordance with this Policy.
12. REDRESS/COMPLIANCE AND ACCOUNTABILITY
Questions or concerns regarding our compliance with this Policy may be directed to
firstname.lastname@example.org or contact us at:
350 Alabama St. Suite 10
San Francisco, CA 94110
AppGrowth will address your concerns and attempt to resolve any privacy issues in a timely
please contact us at the contact information provided above. If any request remains unresolved,
you may contact the national data protection authority for your EU Member State.
13. OTHER RIGHTS AND IMPORTANT INFORMATION
discretion, so review it periodically. If you continue to visit this Website or use
our Services after such changes have been made, you hereby provide your
consent to the changes.
Policy, AppGrowth will notify you by email or as otherwise required by
page, and the revised version will be effective immediately when it is posted
(or upon notice as applicable). If you are concerned about how your information
• New Uses of Personal Information. Additionally, before we use Personal
Information for any new purpose not originally authorized by you, we will
endeavor to provide information regarding the new purpose and give you the
opportunity to opt-out. Where consent of the Individual for the Processing of
Personal Information is otherwise required by law or contract, AppGrowth will
endeavor to comply with the law or contract.
14. CALIFORNIA PRIVACY RIGHTS
California law permits users who are California residents to request and obtain from us once a
year, free of charge, a list of the third parties to whom we have disclosed their Personal Information
(if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal
Information disclosed to those parties. AppGrowth does not share Personal Information with third
parties for their own marketing purposes.