Updated 10/12/2015

This Privacy Policy (“Privacy Policy”) explains how information is collected and utilized by Apsalar, Inc. (“Apsalar” or “we”, “us”, “our”) and its subsidiaries and affiliated companies. This Privacy Policy applies to the Apsalar website at www.apsalar.com (“Website”) and Apsalar’s services (as such services are described in fuller detail in Apsalar’s Terms of Use available at http://apsalar.com/terms-of-use/ (or such other URL as Apsalar may provide from time to time), as such agreement may be reviewed and revised by Apsalar in accordance with the terms thereof, the “Services”).

Information We Collect Within our Mobile Services, for Publishers

Apsalar provides the Services to mobile application publishers. If you are a publisher using Apsalar’s Services, Apsalar may access, index, and cache requests made from your applications to our system, including by automated means. In the course of providing these Services, Apsalar collects non-personally identifiable information regarding the behavior and usage patterns of users of mobile applications and other mobile properties operated by participating mobile application publishers. Apsalar also collects certain information about visitors to publishers’ mobile applications that connect to the Apsalar Services. Apsalar will automatically collect and receive information about those visitors such as, but not limited to, carrier provider, IP addresses, Apple’s ID for Advertising (IDFA), Google Android ID and Advertising ID for Android (AIFA), carrier user “ID”, and geo-location information. In this policy, we refer to this non-personally identifiable information, together with other non-personally identifiable information that we obtain from third parties, as “User Data.” Apsalar also supports the Do Not Track flags requested by Apple and Google. Apsalar purges User Data logs after 18 months.

Use of Personal Information Collected

We use the information we collect to provide our Services and to better understand what products and services are of interest to our users. For example, we may utilize your information to:
• Operate and improve our Website and render the Services;
• Respond to your comments and questions and provide customer service;
• Provide and deliver products and services and send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
• Protect the rights or property of Apsalar or our users; and
• Communicate with you about promotions, upcoming events, and other news about products and services offered by Apsalar and our partners.
We also analyze the non-personally identifiable User Data collected from various mobile applications. We are aware of the sensitivity of certain types of User Data. We do not collect User Data that we consider sensitive. While the types of User Data that may be considered sensitive may vary among users, we presently treat User Data as sensitive if it includes data reflecting a user having any medical or health condition; certain aspects of a user’s personal life or financial situation; racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; sexual orientation or practices; or use of, or interest in, gambling, alcoholic beverages, or “adult” products or services. We may update from time to time the types of User Data that we consider sensitive.

Sharing of Personal Information Collected

Apsalar does not share your personal information except as approved by you or as described below:
• With your consent, for example, when you agree to our sharing your information with other third parties for their own marketing purposes subject to their separate privacy policies.
• Apsalar may engage other companies and individuals to perform services on our behalf. Examples of these services include sending postal mail and e-mail to you and analyzing data. While these agents and service providers may have access to your personal information in connection with the performance of services for Apsalar, they may not use such information for any purpose other than providing such services to Apsalar.
• We release account and other personal information when we believe that release is appropriate to comply with the law; enforce or apply our user Agreement; or protect the rights, property, or safety of Apsalar, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
• Apsalar may share your personal information in connection with any merger, sale of Apsalar assets, or a financing or acquisition of all or a portion of our business by another entity.

Security of Personal Information Collected

Apsalar takes reasonable measures to protect your personal information in an effort to prevent loss, misuse and unauthorized access, disclosure, alteration and destruction. Apsalar cannot, however, ensure or warrant the security of any information that Apsalar receives, including without limitation with respect to vulnerabilities to hacker intrusion and other malicious code.

What Information Can You Access and Change?

You can access, correct or amend certain information about you collected on the Website in the account section. You may opt out of receiving promotional emails from Apsalar by following the instructions in those emails. If you opt out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations. You may also send requests about your contact preferences and other changes to your information, receive further detail on what information about you that we are holding, and otherwise limit our use and disclosure of your information, by emailing privacy@apsalar.com.

Children Under 13 Years of Age

The Services and Website of Apsalar are not intended for persons under 13 years of age. Apsalar’s Services and Website are not developed or directed at children. We do not knowingly solicit or collect any personally identifiable information from children under the age of 13, either directly from users of the Services or Websites or from any other website or online service that is directed to children, nor do we knowingly market our Services or Website to children under the age of 13.

Changes to this Privacy Policy

We may review and revise this Privacy Policy at any time, including without limitation in consultation with third parties and upon changes in relevant laws or interpretations. We encourage you to visit this page periodically to review our current Privacy Policy so that you will always know what information we gather and how we may use that information. In the event we make any material changes to this Privacy Policy we will advise our mobile application publishers of such changes in advance but we may or may not notify individual users or visitors of such changes in advance.

Contacting Us

Questions, comments, or complaints about this Privacy Policy may be emailed to privacy@apsalar.com or mailed to Apsalar, Inc. at 480 Second Street, Suite 100, San Francisco, CA 94107, Attn: Privacy.