PRIVACY POLICY

1. PURPOSE

1.1 AppGrowth Inc. has developed this Privacy Policy (“Policy”) to demonstrate our

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

Employees.

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.

2. SCOPE

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

this Policy.

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

“Individuals”).

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

Advertising

We, as well as third parties that provide content, advertising, or other functionality on our Services

or Website, may use cookies, pixel tags, local storage, mobile device identifiers and other

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

Website.

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

are governed by the privacy policy of the company providing it.

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

Website;

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

and Services;

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

include:

o To tailor content, advertisements, and offers;

o To notify you about offers, products, and services that may be of interest to

you;

o To provide Services to you and our sponsors;

o For other purposes disclosed at the time that Individuals provide Personal

Information;

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

purposes.

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

below.

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

data in accordance with your privacy policy and all applicable laws in any country in which your

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

INFORMATION

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

your permission.

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

to them.

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

6.1 General

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

websites that contain the AdChoices link and that link to this Privacy Policy may have been

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

info@appgrowth.com 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.

9. RETENTION

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 info@appgrowth.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

account.

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

terms contained in this Privacy Policy will be governed by the laws of the state of California in 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

info@appgrowth.com or contact us at:

AppGrowth Inc.

350 Alabama St. Suite 10

San Francisco, CA 94110

AppGrowth will address your concerns and attempt to resolve any privacy issues in a timely

manner.

If you are an EU citizen and feel that AppGrowth is not abiding by the terms of this Privacy Policy,

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

13.1 Changes to Our Privacy Policy And Practices

This Privacy Policy may change from time to time. You understand and agree that you will be

deemed to have accepted the updated Privacy Policy if you use the Services or Website after the

updated Privacy Policy is posted on the Services or Website. If at any point you do not agree to

any portion of the Privacy Policy then in effect, you must immediately stop using the Services.

Revision to the Privacy Policy. We may revise this Privacy Policy in our sole

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.

Posting of Revised Privacy Policy. If there are any material changes to this

Policy, AppGrowth will notify you by email or as otherwise required by

applicable law. We will post any adjustments to the Privacy Policy on this web

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

is used, bookmark this page and read this Privacy Policy periodically.

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.

The last update to our Privacy Policy was posted on May 25, 2018.