GENERAL

We respect the privacy of our online users and re committed to protecting the information you provide to us. The following Free App Analytics Privacy Policy (“Privacy Policy“) relates solely to Free App Analytics and users of the website www.freeappanalytics.com. In particular, we believe it is important for users to know how we treat information that we may receive or collect in connection with Customers utilizing our Services or by visiting www.freeappanalytics.com. This Privacy Policy intends to explain the conditions under which Free App Analytics may use and disclose certain information. It also intends to explain your rights in relation to that information.

  DEFINITIONS

Attribution: An analytics model in which a user event is ascribed to a marketing activity. For example, a user may click on an advertisement, download an app, or make an in-app purchase – each of these actions is a user event in which the Platform performs Attribution. Customer: A person or company that promotes its product or a component of its product using the Platform. For example, a Customer may promote its mobile application, a specific promotion within its app, an app update, an event, or a company announcement, and use the Platform to perform Attribution for such events. Free App Analytics: Kochava, Inc., a Delaware corporation with its principal place of business located in Sandpoint, Idaho. Geographic Location Data: Non-precise, geographic data that determines location from IP address, GPS coordinates and/or Wi-Fi networks. For example, a Customer may collect Geographic Location Data from an IP address through the Platform to gain further insight into the performance of an advertising campaign. Non-Personally-Identifying Information: Information that, without the aid of additional information, cannot be directly associated with a specific person. Partner: A third-party with whom a Customer works to promote applications, networks, offers, and/or advertisements, including, but not limited to, ad networks, publishers, advertisers, affiliates, analytics providers, and data providers. Personally-Identifying Information: Information that can be directly associated with a specific person without any additional data. Platform: A back-end technology that provides Attribution using Unique Advertising Identifiers and/or Statistical Identifiers to measure the performance of a mobile ad campaign. Platform SDK: A computer code included in a developer’s mobile app to enable the developer to collect Unique Advertising Identifiers and Statistical Identifiers from the user for the purpose of measuring performance. Postbacks: Server-to-server communication that allows a party to share information. Statistical Identifiers: A method of providing Attribution when Unique Advertising Identifiers are unavailable. Statistical Identification involves the collection of publicly-available HTTP headers from an end user’s device. The Platform uses the HTTP headers to probabilistically determine which device is responsible for the Attribution and collects the following data points: country code, device brand, device model, device carrier, IP address, language preference, operating system name, operating system version, user agent (browser type), and timestamp. Unique Advertising Identifiers: Unique, user-specific character strings for advertising, which may be reset by the user. Examples of Unique Advertising Identifiers include IDFA (developed by Apple for the iPhone), Google Ad ID (developed by Google for Android), and Windows advertising ID (developed by Microsoft for the Windows Phone). Vendor: A company that provide services to Free App Analytics. Web Beacon: Code that is embedded in a web page that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page. Web Cookie: A string of information that a website stores on a user’s computer, and that the user’s browser provides to the website each time the user submits a query to that website.

  EU – U.S. Privacy Shield
EU-US Privacy Shield

Free App Analytics distributes and stores all of the information it collects in secure servers located in the United States. Any personal information that you provide to Free App Analytics will be hosted on United States servers. Free App Analytics adheres to, and self-certifies compliance with, the EU – U.S. Privacy Shield Principles and the U.S. – Swiss Safe Harbor framework. As such, Free App Analytics is subject to the investigatory and enforcement powers of the FTC for purposes of compliance with Privacy Shield. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles govern. Free App Analytics primarily processes personal data as an agent on behalf of and under the instruction of third-parties. You may have the right to contact such third-parties directly to limit or stop them from sharing your personal information with Free App Analytics. In the event that Free App Analytics processes your personal information as a principal, you have the right to access this data and to direct Free App Analytics to not disclose it to third-parties. In compliance with the Privacy Shield Principles, Free App Analytics commits to resolve complaints about your privacy and our collection or use of your personal information. European Union citizens with inquiries or complaints regarding this privacy policy should first contact support at privacy@freeappanalytics.com. Free App Analytics has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, Privacy Trust, located in London, England. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit the Privacy Trust website at https://www.privacytrust.com for more information and to file a complaint. Please note that if your complaint is not resolved through these channels, in certain limited circumstances, a binding arbitration option may be available before the Privacy Shield Panel. Pursuant to the Privacy Shield Principles, Free App Analytics may be required under certain circumstances to disclose personal information in response to lawful requests by public authorities. To learn more about the Privacy Shield program, or to view our certification, please visit: https://www.privacyshield.gov/. To learn more about the Swiss Safe Harbor program, please visit: http://2016.export.gov/safeharbor/.

  VISITORS TO OUR WEBSITE

Information Collected by Free App Analytics As a visitor to our site, you can browse our pages without having any Personally Identifiable Information revealed about you. Information we automatically collect via industry standard web log files and other tools includes the URL from which you visited, the page you are visiting, your computer browser information, and your IP address. Free App Analytics uses Web Cookies to track the pages that users visit during each website session, both to help us improve users’ experiences and to help us understand how the website is being used. As with other Non-Personally-Identifying Information gathered from users of the website, Free App Analytics analyzes and discloses in aggregated form information gathered using Web Cookies, so as to help Free App Analytics, its partners and others better understand how the website is being used. Free App Analytics does not attempt to link information gathered using Web Cookies to Personally-Identifying Information. FREE APP ANALYTICS USERS WHO DO NOT WISH TO HAVE WEB COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO REFUSE WEB COOKIES BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES. WEBSITE USERS WHO REFUSE WEB COOKIES ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY. Free App Analytics may use Web Beacons on the Website to count users who have visited particular pages and to deliver co-branded services. Web Beacons are not used to access users’ Personally-Identifying Information; they are a technique Free App Analytics may use to compile aggregated statistics about website usage. Web Beacons collect only a limited set of information including a cookie number, time and date of a page view, and a description of the page on which the Web Beacon resides. As defined above, Personally-Identifying Information is information that can be directly associated with a specific person without any additional data. There are portions of our website, www.freeappanalytics.com, where we may need to collect Personally-Identifying Information from you for a specific purpose, such as to provide you with certain information you request. The information collected from you may include your name, address, telephone, fax number, e-mail address, and other personal information. Users of our website are under no obligation to provide Free App Analytics with Personally-Identifying Information of any kind; however, a user’s refusal to do so may prevent the user from using certain website features. BY REGISTERING WITH THE WEBSITE, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY-IDENTIFYING INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. Use and Disclosure of Information by Free App Analytics Free App Analytics gathers information on behalf of our Customers for the purposes of: providing you and our Customers with custom information about our service offerings that support your business needs; matching you and our Customers with compatible participants in our partner program in the event that we are unable to support your business needs ourselves; and reviewing your application for employment if you are seeking work. We recognize that certain information may be sensitive. As such, we restrict our collection of such information to the critical data needed to deliver our services. If you use the forms on our website, you may receive emails from us to facilitate your inquiry. You cannot opt out of emails that are necessary to provide our services. By using our forms or accepting the Free App Analytics Terms of Service, you agree that we and our partners may use your Personally-Identifying Information to contact you and deliver information to you. We may share your Personally-Identifying Information with Vendors and Customers. Our Vendors and Customers are contractually restricted from using your Personally-Identifying Information for any purpose that exceeds the scope of the contractual relationship. Furthermore, our Vendors and customers are prohibited from disclosing your Personally-Identifying Information to anyone else. We may also share your Personally-Identifying Information with compatible participants in our partner program in the event that we are unable to meet your business needs. Collection of Customers’ Data Customers submit their full name, mailing and/or billing address, email address, company name, and website URL. We use Customers’ information to service Customer accounts and respond to inquiries. We hold all such information in strict confidence. Information Security & Storage Duration We maintain strict physical, electronic, and administrative safeguards to protect any Personally-Identifying Information submitted by you from unauthorized or inappropriate access. We restrict access to information about you to those Free App Analytics employees and Customers who need to know the information to respond to your inquiry or request. Employees who misuse Personally-Identifying Information are subject to disciplinary action.

Information of Minors This website is not intended for persons under 13 years of age. We do not knowingly solicit or collect Personally-Identifying Information from or about children, and we do not knowingly market our products or services to children. Links to Other Sites Free App Analytics’ website may contain links to other websites such as distributors and sales affiliates. While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites. Free App Analytics neither owns nor controls the third-party websites accessible through our website. Thus, this Privacy Policy does not apply to information provided to or gathered by the third-parties that operate them. Before visiting a third-party, whether by means of a link on the website or otherwise, and before providing any Personally-Identifying Information to any third-party, users should inform themselves of the privacy policies and practices (if any) of the third-party responsible for that website, and should take those steps necessary to, in those users’ discretion, protect their privacy. Access & Opt-Out You may review, update, or request the deletion of the information that you provide to us through this website by contacting us as described below.   INFORMATION COLLECTED BY CUSTOMERS UTILIZING THE PLATFORM

Non-Personally-Identifying Information The Platform is designed to collect and use data such as Unique Advertising Identifiers, Statistical Identifiers, Geographic Location Data and other data provided by the Customer for Attribution. When an end user clicks on an advertisement, installs an app, or takes an action inside of an app, the Platform employs the Platform SDK to redirect links for purposes of collecting information, such as a Unique Advertising Identifier, to perform Attribution. The Platform also enables Customers to view and measure Non-Personally-Identifying Information provided by Free App Analytics, Customers, and the Customers’ other partnerships. Customers and Partners may also send Non-Personally-Identifying Information to the Platform via Postback. The Platform does not collect names, addresses, phone numbers, or financial information (like credit cards or banking information) from end users.

Personally-Identifying-Information Free App Analytics does not choose or determine the types of data that are submitted to Free App Analytics’ servers, because such data collection is determined and submitted by its Customers. Free App Analytics’ Customers are contractually prohibited from transmitting Personally-Identifying Information to Free App Analytics. Under certain circumstances, IP Address may be considered personal data under the EU’s 1995 Data Protection Directive. As a precaution, we adhere to the EU – U.S. Privacy Shield and US-Swiss Safe Harbor frameworks due to the possibility that the European Data Protection Authority might deem some of the information we collect to be personal data. For more information regarding our EU privacy standards, see EU – U.S. PRIVACY SHIELD above. Information Security & Storage Duration We maintain strict physical, electronic, and administrative safeguards to protect all information submitted to Free App Analytics by our Customers. Customer Use of Data Collected Through the Platform Customers use information collected through the Platform to view reports and data related to their advertising campaigns. The Platform allows Customers to view and utilize the information to optimize advertising campaigns. Customers may also use the Platform to share their data with Partners, including measurement partners, advertising networks, and publishers, via Postback, data exports, and/or API calls. Customers may use the information they collect on the Platform for the following purposes, which include, but are not limited to:
  • Measuring the performance of ad campaigns (for example, by comparing the lifetime value of a user against the expenses required to obtain that user);
  • Measuring the value of particular end users;
  • Measuring the performance of various Partners, including ad networks and publishers;
  • Creating customized performance reports (for example, how well a particular advertisement is performing in a particular geographic region);
  • Determining when end users respond to ads; and
  • Device attribution.
Third-Party Disclosure Free App Analytics contractually prohibits its contractors, affiliates, Vendors and suppliers from disclosing Personally-Identifying Information received from Free App Analytics, other than in accordance with this Privacy Policy. Third-parties are under no obligation to comply with this Privacy Policy, with respect to Personally-Identifying Information that users provide directly to those third-parties or that those third-parties collect for themselves. Free App Analytics may share aggregated data derived from the Services, including, for example, statistics about Services activity. In the event of Free App Analytics merging with or selling to another business entity, your Personally-Identifying Information will be protected by our Privacy Policy. As a good corporate citizen, Free App Analytics is interested in protecting the community at large. We will release Personally-Identifying Information to legal authorities when we believe it is appropriate to comply with the law. In addition, Free App Analytics may choose to release information about you to relevant parties in relation to investigations of fraud, piracy, or other unlawful activity. Access & Opt-Out Users who wish to opt out of a particular ad network, publisher, or advertiser’s ads must contact those companies directly to opt out.   CONTACTING US
We welcome your questions and suggestions about this Privacy Policy. You may direct your correspondence to support@freeappanalytics.com or, if by U.S. Mail, to Free App Analytics, Attn: Legal Dept., 201 Church Street, Sandpoint, ID 83864.   CHANGES TO THIS POLICY

Please check this Privacy Policy periodically to inform yourself of any changes. We reserve the right to modify or supplement this Privacy Policy at any time. The current version of this Privacy Policy will apply. Accordingly, each time you use the web site you should check the date of this Privacy Policy (which appears at the end of this document) and review any changes since the last time you used the web site. This Privacy Policy is effective as of and was last updated on September 13, 2016.