Privacy Policy of AppFillip CPI

1. General

This is the privacy policy of AppFillip CPI, (heretoafter referred to as "AppFillip CPI") which applies to all AppFillip CPI websites and services.

This privacy policy of AppFillip CPI is intended for all users of the AppFillip CPI websites and services ("user"). The AppFillip CPI services relate primarily to advertising from third parties ("advertising partners") on websites and services operated by other third parties ("publishers") as well as advertising via the own assets operated by AppFillip CPI (“services”) and third parties (“resellers”) using the assets of AppFillip CPI in order to publish advertisements from their own advertising partners. Therefore users are mainly advertisers, publishers, resellers and other interested parties or their employees. Among the users are also users of services on the Internet provided by publishers and resellers ("publisher-user") as well as other private users who are in direct contact with us.

All personal information that AppFillip CPI collects through users by the use of the websites and services that users voluntarily submit and provide in the course of all business relations will handled by AppFillip CPI in regards to applicable data protection legal provisions.

AppFillip CPI saves and uses data to prevent and combat fraud and abuse on AppFillip CPI websites and services and to offer services adapted to our users. All details are laid out in this privacy policy.

2. Application of Privacy Policy

This privacy policy is only applicable to the websites and services of AppFillip CPI. It does not apply to the websites and services of the publishers. In the event that the user is forwarded, for instance via redirect, link or an advertisement, to another website or service not operated by AppFillip CPI, the user will be informed by AppFillip CPI that this document does not apply to website or service concerned. AppFillip CPI declares to not be responsible for the way the operator of the other website handles data. In particular, AppFillip CPI is not responsible that this privacy policy does not apply on websites and services not operated by AppFillip CPI. AppFillip CPI recommends to all users to always read and check carefully the privacy policy of third party websites.

3. User Personal Information

AppFillip CPI collects, processes and stores personal information from the user that the user voluntarily submits via forms on the website or services or elsewhere operated by AppFillip CPI in electronic or any other form of communication. To register to use the websites or services from AppFillip CPI the user needs to submit certain personal information. This includes among other things names and email address.

4. Storage of Information

Usage Data:

When a user makes use of websites or services operated by AppFillip CPI, AppFillip CPI automatically saves through usage of cookies the domain name and/or IP address of the computer used to contact AppFillip CPI as well as the date, length of visit at website or service operated by AppFillip CPI, pages accessed by the user and browser used.

Mobile Use of the Services:

Via smarphones, tablets or other mobile devices users can also access content and services from AppFillip CPI. AppFillip CPI then stores the device's identification number (i.e. ANDROID_ID, IMEI, MAC Adresses) that accesses the content or service in an anonymized form as well as the standard technical information (i.e. operating system version, device type, and so on) to enable the user to access the content or service.

Email Address:

If submitted, AppFillip CPI stores the email addresses of its users. Users either submit their email address voluntarily via contact form or by submitting it in the course of direct communication with AppFillip CPI.

Information via Communication:

AppFillip CPI saves the history of communication, when the user submits a ticket to AppFillip CPI customer support as well as the information submitted by the user in the course of the communication (i.e. email address). AppFillip CPI does this in order to answer the user inquiry as best as we can. We do not share this information with third parties.

Other voluntarily submitted Information:

Our main concern is to always try to improve our offers and services as well as to adapt them to its users as best as we can. In the course of that approvement process the user can submit additional information to AppFillip CPI as part of the use of offers and services operated by AppFillip CPI or in the course of direct communication. Information stored are such as name, address, age, gender, interests and, if applicable, payment data. Payment data is only stored if the user processes a payment via AppFillip CPI. The user can also allow AppFillip CPI to record their usage behavior on partner websites.

5. Third Party Information Gathering

Usage data from Publishers (publisher-user):

Publishers who work with AppFillip CPI share information about behavior of the publisher-user's usage. AppFillip CPI needs the publisher-user's data in order for the the user to receive benefits for offers from the publisher. By doing so, the publisher assigns each user a personal ID ("UserID") connected with the usage data. The UserID can only be read out by the publisher. AppFillip CPI is not able to directly associate the usage data shared by the publisher via the UserID with the user. AppFillip CPI can only determine the identity of the publisher-user if the publisher-user itself initiates such a request.

Thus, the information transmitted by the publisher to AppFillip CPI is not related to one individual. This applies unless the publisher-user disclosed its identity and therefore waiving the protection of his private information (for instance accessing the publisher's content with a user name connected to the real name or entering the email address on the publisher's website). In this case, but not solely, AppFillip CPI is entitled to the above-mentioned rights to use the personal information.

Nevertheless publisher-users should check the privacy policy of the publisher's website in regard to the publisher's handling of personal information.

6. Use of Personal Information

Optimization of the service:

AppFillip CPI collects, processes, and stores users' personal information, when seeing a legitimate business purpose for it. Expressed in a different way AppFillip CPI collects, processes, and stores user data to better understand users of their websites and services and therefore offer them better services. For instance AppFillip CPI can not only use the information stored for direct processing of the agreement concluded with the user (for example use of services, creation of invoices, use of customer support), but also use it to identify malfunctions and/or misuse of AppFillip CPI websites and services.

Prevention and combat of abuse:

Thus, AppFillip CPI logs and stores information on the use of AppFillip CPI websites and services such as activity on the publisher's website and service in regard to customers' advertisements or services, including the monitoring of behavior patterns and checking for manipulations. This can be useful and therefore is used to detect misuse or improper activity by the user or publisher-user. AppFillip CPI uses special software to detect the use of illicit scripts and identify the IP address as well as other data in regard to the behavior of users and publisher-users. If AppFillip CPI determines that a user or publisher-user violates its contractual obligations, for instance by using illicit scripts, AppFillip CPI explicitly reserves the right to bring the user's or publisher-user’s data together with other data stored by AppFillip CPI on this person to prove the violation. We will then possibly take additional measures against the users or publisher-users concerned to restore normal operation.

Billing of services:

Insofar as it is required for billing, AppFillip CPI is entitled to share user data with the service provider responsible for payment processing. AppFillip CPI is also entitled to provide user data to third parties authorized to collect outstanding balances, insofar as this information is required or useful to collect the balance. When cooperating with third parties for these services, AppFillip CPI will obligate them to observe applicable data protection laws and guarantee sufficient data protection.

Market research:

AppFillip CPI is entitled to anonymously use the information stored by and from the user or publisher-user to evaluate interests, user behavior and demography. AppFillip CPI is also entitled to anonymously analyze information stored about the user or publisher-user in an statistical and aggregate form. If and to the extent to which AppFillip CPI uses data to create user profiles, AppFillip CPI will never share the profiles with third parties without the consent of the person concerned and will immediately cease the use of the user profile if the user or publisher-user objects to it.

Personalized offers:

Based on the information submitted to AppFillip CPI as well as the actions within AppFillip CPI websites and services, AppFillip CPI may allow third parties to contact the user for advertising purposes. As long as the user does not object to the use of its user data for this purpose, advertising can be sent that matches his or her profile and interests. The information cannot be attributed to the user, unless the user voluntarily made this information on a website or service operated by AppFillip CPI.

Email Address:

The email addresses acquired through an offer form of AppFillip CPI or received directly from the user can be used by AppFillip CPI to send the user newsletters and information on AppFillip CPI offers. The user can withdraw this consent by objecting at any time via email at no charge. The user will have the opportunity in every information and newsletter sent by AppFillip CPI to unsubscribe or send a cancellation notice via mail.

If the user voluntarily shares personal information on request by AppFillip CPI , then AppFillip CPI will use this information with his or her consent so that the user receives personalized special offers.

7. Sharing of Personal Information

User Data:

Personal and pseudonymized user data is used solely by AppFillip CPI. It is not shared with third parties. Information received by third parties about user behavior is received only without being able to attribute it to a specific person.

Personal Information:

AppFillip CPI will use and when necessary share personal information in the course of fraud prevention and detection.

AppFillip CPI will transmit user's personal information to advertisers and resellers only when the user redeems a promotional offer of such a partner company participates in a survey and the information is required for processing or for participation in the survey.

AppFillip CPI will not provide third parties with email addresses or information from the communication with customer support or other information volunteered to AppFillip CPI.

8. Changing or Deleting Personal Information

The user and publisher-user can change or delete his personal information at any time. The user or publisher-user can as well contact AppFillip CPI, if they would like AppFillip CPI to change or stop using their information. AppFillip CPI will change or delete the user's or publisher-user's information as quickly as possible. However, AppFillip CPI points out that due to technical and organizational constraints, it is possible that some ongoing measures or those that have not yet begun may continue to be carried out after the request for deletion to AppFillip CPI has been made.

9. Disclosure of personal information

AppFillip CPI will disclose all of the information stored about the user or publisher-user immediately and unchanged on request by the user or publisher-user. The information will always be conveyed in electronic form via email. Exceptions might be made after consulting the AppFillip CPI support.

10. Changes to the Privacy Policy

While observing current data protection laws AppFillip CPI reserves the right to change this privacy policy at any time. Therefore AppFillip CPI recommends to regularly inform yourself about the current privacy policy stated here. In the event that AppFillip CPI intends to use personal user or publisher-user information on a larger scale than it has been used up to now, AppFillip CPI will announce this beforehand.

11. Support and Contact

For any questions regarding the Privacy Policy or other matters please contact us.

When contacting us, we keep a record of that correspondence and collect your email adress and other information in that matter as stated above. This will only happen for archival purposes as well as for further correspondence and optimization of our website and services. Your email adress will not be used, transfered or sold.

AppFillip CPI