This Cookie Policy explains how Appic Management (“Appic” “we”, “us” or “our”) and our subsidiaries and affiliates (together the “Appic Group”) use cookies and similar technologies in connection with any other website that we own or control and which posts or links to this Cookie Policy (collectively, the “Sites”).
The website www.appic.io does not make use of cookies.
Cookies are small data files that are placed on your computer or mobile device when you visit a website.
Cookies serve different purposes, like helping us understand how a site is being used, letting you navigate between pages efficiently, remembering your preferences and generally improving your browsing experience.
Our Sites may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them).
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Sites; and (2) third party cookies, which are served by service providers or business partners on our Sites, and can be used by these parties to recognize your computer or mobile device when it visits other websites. Third party cookies can be used for a variety of purposes, including site analytics, advertising and social media features.
On the Sites, we use cookies and other tracking technologies in the following categories described below.
Type: Remarketing
Description: These cookies are used by advertising companies to collect information about how you use our Sites and other websites over time. These companies use this information to show you ads they believe will be relevant to you within our services and elsewhere, and to measure how the ads perform.
Who serves the cookies: Google Analytics
Google Analytics uses its own cookies. You can find out more information about Google Analytics cookies here and about how Google protects your data here. You can prevent the use of Google Analytics relating to your use of our Sites by downloading and installing a browser plugin available here.
Type: Conversion
Description: These cookies are used to enable us to track your actions across our sites in order to capture the number of conversions completed by users.
Who serves the cookies: Google Analytics
How to control them: See ‘Your Choices’ below.
Type: Analytics
Description: These cookies help us understand how our services are performing and being used. These cookies may work with web beacons included in emails we send to track which emails are opened and which links are clicked by recipients.
Who serves the cookies: Google Analytics
How to control them: See ‘Your Choices’ below.
Type: Essential
Description: These cookies are necessary to allow the technical operation of our services (e.g., they enable you to move around on a website and to use its features).
Who serves the cookies: Google Tag Manager
How to control them: See ‘Your Choices’ below
Type: Functionality/performance
Description: These cookies enhance the performance and functionality of our services. These are used to recognise you when you return to our website.
Who serves the cookies: Intercom
How to control them: See ‘YourChoices’ below.
In addition to cookies, our Sites may use other technologies, such as Flash technology to pixel tags to collect information automatically.
We may use browser web storage (including via HTML5), also known as locally stored objects (“LSOs”), for similar purposes as cookies. Browser web storage enables the storage of a larger amount of data than cookies.
Your web browser may provide the functionality to clear your browserweb storage.
We may use Flash cookies (which are also known as Flash Local Shared Object (“Flash LSOs”)) on our Sites to collect and store information about your use of our Sites. Unlike other cookies, Flash cookies cannot be removed or rejected via your browser settings. If you do not want Flash LSOs stored on your computer or mobile device, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions. Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our Sites.
We may also use web beacons (which are also known as pixel tags and clear GIFs) on our Sites and in our HTML formatted emails to track the actions of users on our Sites and interactions with our emails. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages or within HTML formatted emails. Pixel tags are used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of the Sites, so that we can manage our content more effectively.
Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings.
Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Sites may not work properly.
If you do not accept our cookies, you may experience some inconvenience in your use of our Sites. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Sites.
Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. European users may opt out of receiving targeted advertising on websites through members of the European Interactive Digital Advertising Alliance by clicking here, selecting the user’s country, and then clicking “Choices” (or similarly-titled link). Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.
If you choose to opt-out of targeted advertisements, you will still see advertisements online, but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioural advertising are included in this list, and so you may still receive some cookies and tailored advertisements from companies that are not listed.
For more information about how we collect, use and share your information, see our Privacy Policy here.
Information about the cookies we use may be updated from time to time, so please check back on a regular basis for any changes.
If you have any questions about this Cookie Policy, please contact us by email at legal@tbaventure.com.
Appic Management S.à r.l, Privacy Notice
Last updated 14 October 2022
This Privacy Notice describes the privacy practices of Appic Management S.à r.l. (“Appic", "we", "us", "our") and our subsidiaries and affiliates (together the “Appic Group”).
Appic cares about privacy and protecting the Personal Data handled by us. In this Privacy Notice we describe how and the purposes for which we use your Personal Data as well as on what lawful basis we use and what measures we take to protect Personal Data. We also provide information on how you can exercise the rights you have linked to our Processing of Personal Data.
Appic is the Controller of all Personal Data listed in this Privacy Notice.
Appic acquires, developsand markets software, mobile and web-based applications that operate on Apple’s App Store and Google’s Play Store, amongst other platforms.
This Privacy Notice explains how we handle the personal information of:
Business owners and developers who look to sell their mobile applications to us; and
Consumers who interact with us or mobile applications in our portfolio (“Portfolio Apps”) through the App Store or Google Play or visit our website: www.appic.io, or other sites we own and operate.
If you buy products or services from one of our Portfolio Apps, this Privacy Notice explains how we will process your information. The Processing of your information is also governed by the privacy statements of the App Store and Google Play. Depending on the territory in which you are located, other privacy policies or statements may apply.
Some of our Portfolio Apps may also have direct-to-consumer websites that have their own specific privacy notices and policies. Where applicable, our Processing of the information we collect on the Portfolio Apps’ sites is governed by the privacy notices and policies of those Portfolio Apps.
"Applicable Law" refers to the legislation applicable to the Processing of Personal Data, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (“GDPR”), supplementary national legislation, as well as practices, guidelines and recommendations issued by a national or EU supervisory authority.
"Controller" is the company/organisation that decides for what purposes and in what way personal data is to be processed and is responsible for the Processing of Personal Data in accordance with Applicable Law.
"Data Subject" is the living, natural person whose Personal Data is being processed.
"Personal Data" is all information relating, directly or indirectly, to an identifiable natural person.
"Processing" means any operation or set of operations which is performed on Personal Data, e.g. storage, modification, reading, handover and similar.
"Processor" is the company/organisation that processes Personal Data on behalf of the Controller and can therefore only process the Personal Data according to the instructions of the Controller and the Applicable Law.
The definitions above shall apply in the Privacy Notice regardless if they are capitalised or not.
The information in this Privacy Notice covers Personal Data Processing for which Appic is the Controller. As a Controller we are responsible for the Processing for which we decide the purpose of and the means for the Processing (what methods, what Personal Data and for how long it is stored). This Privacy Notice does not describe how we Process Personal Data in the role of a Processor - i.e. when we process Personal Data on behalf of our customers.
We have a responsibility to describe and demonstrate how we fulfil the requirements that are imposed on us when we Process your Personal Data. This section aims to give you an understanding of what type of Personal Data we Process, how and why we do it.
There are several different reasons why we may need to collect, manage and save your data. The main purpose of the data processing undertaken by us is to provide, carry out and improve the services offered by us and/or our Portfolio Apps to you.
We mainly process the following types of Personal Data:
We collect your Personal Data in a number of different ways. We mainly get access to your Personal Data:
In order for us to be able to process your Personal Data, it is required that we have so-called legal basis for each process. In our business, we process your Personal Data mainly on the following grounds:
Consent: Appic may process your personal data after you have given your consent to the Processing. Information regarding the processing is always provided in connection to the request of consent.
Performance of a contract: The Processing is necessary for the performance of a contract entered between us and the Data Subject, or to prepare for entering into an agreement with the Data Subject.
Legitimate interest: Appic may process Personal Data if we have assessed that a legitimate interest overrides the interest of fundamental rights and freedoms of the Data Subject, and if the processing is necessary for the purpose in question.
Legal obligation: We are required by laws and regulations to process Personal Data as a result of our business.
Examples of the specific purpose or activity that we will use your Personal Data for, the type of Personal Data and the lawful basis for Processing that data are set out below. This is a non-exhaustive list.
Purpose/activity | Type of Personal Data | Lawful basis for processing |
---|---|---|
To install the Portfolio Apps and register you as a new Portfolio App user | Identity Contact Financial Device |
Your consent |
To process in-App purchases and deliver services including managing payments and collecting money owed to us | Identity Contact Financial Transaction Device Marketing and Communications Location |
Your consent Performance of a contract with you Necessary for our legitimate interests (to recover debts) |
To manage our relationship with you including notifying you of changes to the Portfolio Apps or any services | Identity Contact Financial Profile Marketing and Communications |
Your consent Performance of a contract with you Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/services) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions) |
To enable you to participate in a prize draw, competition or complete a survey | Identity Contact Device Profile Marketing and Communications |
Your consent Performance of a contract with you Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business) |
To administer and protect our business and the Portfolio Apps including troubleshooting, data analysis and system testing | Identity Contact Device |
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security) |
To deliver content and advertisements to you To make recommendations to you about goods or services which may interest you To measure and analyse the effectiveness of the advertising we serve you To monitor trends so we can improve the Portfolio Apps |
Identity/Contact/Device/Content/Profile/Usage/Marketing and Communications/Location | Consent Necessary for our legitimate interests (to develop our products/Services and grow our business) |
We will keep your Personal Data as long as it is necessary for the purpose for which it was collected. Depending on the lawful basis on which we support the Processing, this may: (a) be regulated in a contract, (b) be dependent on valid consent, (c) be stated in legislation, or (d) following an internal assessment, be based on a legitimate interest assessment (“LIA”).
For purposes of compliance with applicable legislation (including tax) we are required by law to keep some basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers.
We never store your Personal Data longer than is necessary and delete Personal Data regularly. Appic also takes reasonable actions to keep Personal Data updated and to delete outdated and otherwise incorrect or redundant Personal Data.
In some circumstances we will anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
In the event that you do not use a Portfolio App for a period of six years then we will treat the account as expired and your Personal Data may be deleted.
You are the one in control of your Personal Data and we always strive to ensure that you can exercise your rights as efficiently and smoothly as possible.
Access: You always have the right to receive information about the Processing of data that concerns you. We only provide information if we have been able to verify that it is you that is requesting the information.
Rectification: If you find that the Personal Data we process about you is incorrect, let us know and we will fix it!
Erasure: Do you want us to completely forget about you? You have the right to be forgotten and request deletion of your Personal Data when the Processing is no longer necessary for the purpose for which it was collected. If we are required to retain your information under applicable law or a contract that we have entered with you, we will ensure that it is processed only for the specific purpose set forth in such applicable law or contract. We will thereafter erase the information as soon as possible.
Objections: Do you disagree with our assessment that a legitimate interest for Processing your Personal Data overrides your interest in protecting your privacy? Don't worry - in such case, we will review our LIA. Of course, we add your objection to the balance and make a new assessment to see if we can still justify our Processing of your Personal Data. If you object to direct marketing, we will immediately delete your personal information without making an assessment.
Restriction: You can also ask us to restrict our Processing of your Personal Data:
Data portability: We may provide you with the data that you have submitted to us or that we have received from you in connection with a contract that we have entered with you. You will receive your information in a commonly used and machine-readable format that you can transfer to another personal data manager.
Withdraw consent: If you have given consent to one or several specific Processing(s) of your Personal Data, you have the right to withdraw your consent at any time and thus ask us to terminate the Processing immediately. Please note that you can only withdraw your consent for future Processing of Personal Data and not for Processing that has already taken place.
Contact us at legal@appic.io and we will help you.
In order to run our business, we may need help from others who will process Personal Data on our behalf, so-called Processors.
In cases where our Processors transfer Personal Data outside the EU/EEA, we have ensured that the level of protection is adequate, and in compliance with Applicable Law, by controlling that either of the following requirements are fulfilled:
the EU Commission has determined that the level of protection is adequate in the third country where the data is processed;
the Processor has signed up to the EU Commission's standard contract clauses (SCCs) for data transfer to non-EU/EEA countries; or
the Processor has taken other appropriate safeguards prior to the transfer and that such safeguards comply with Applicable law.
We may also need to disclose your personal information to certain designated authorities in order to fulfil obligations under applicable law or legally binding judgements.
Appic does not sell your Personal Data to third parties and of course we do not share your Personal Data with just anyone. However, in some cases we may need to share your Personal Data with selected third parties. If so, we make sure that the transfer happens in a secure way that protects your privacy. Set out below are categories of recipients with whom we may share your data.
Within our group. We may share your personal information between our subsidiaries and affiliates for the purposes of monitoring and optimising business performance and to improve the services which we provide to our customers
Service providers. We may share your personal information with third-party companies and individuals that provide services on our behalf or help us operate our website and services (such as customer support, hosting, analytics, email delivery, marketing, and database management services).
Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.
Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporatedivestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution. In such a case, we will make reasonable efforts to require the recipient to honour this Privacy Notice.
Our website may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.
We use reasonable organizational, technical and administrative measures designed toprotect against unauthorized access, misuse, loss, disclosure, alteration and destruction of personal information we maintain.
Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information. In the event that we are required to notify you about a situation involving your data, we may do so by email or telephone to the extent permitted by law.
If you think that we are not Processing your Personal Data correctly, even after you have notified us of this, you are always entitled to submit your complaint to the Luxembourg Authority for Privacy Protection.
More information about our obligations and your rights can be found at www.cnpd.lu.
You can contact the authority via e-mail at: info@cnpd.lu.
We reserve the rights to make changes to this Privacy Notice. In the event that the change affects our obligations or your rights, we will inform you about the changes in advance so that you are given the opportunity to take a position on the updated notice.
Please contact us at legal@appic.io if you have questions about your rights or if you have any other questions about how we process your personal information.
This section applies only to California residents. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.
Please note that the www.appic.io website is designed for businesses and not intended for personal or household use. Accordingly, we treat all personal information about any visitors to www.appic.io as pertaining to individuals acting as business representatives, rather than in their personal capacity.
We do not sell personal information. Like most companies, we use cookies and other tracking tools to analyze website traffic and facilitate advertising. If you would like to opt out of our (and our third party advertising partners) use of cookies and other tracking technologies, please review the instructions provided in our Cookie Policy here.
The CCPA grants individuals whose information is governed by the CCPA the following rights:
Information. You can request information about how we have collected and used your Personal Information during the past 12 months. We have made this information available to California residents without having to request it by including this Privacy Notice
Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
Deletion. You can ask us to delete the Personal Information that we have collected from you.
Opt-out of sales. If we sell your Personal Information, you can opt-out. In addition, if you direct us not to sell your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.
You are entitled to exercise the rights described above free from discrimination.
Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.
How to exercise your rights
You may exercise your California privacy rights described above as follows:
Right to information, access and deletion. You can request to exercise your information, access and deletion rights by: emailing legal@appic.io, by mailing us directly at 121, Avenue de la Faïencerie L - 1511, Luxembourg.
Right to opt-out of the “sale” of your Personal Information. We do not sell your Personal Information.
Identity verification. We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.