DEVTODEV PRIVACY POLICY

This Privacy Policy provides information on Devtodev’s practices in respect of processing personal data it receives as a result of its marketing activities which includes (i) use of the Devtodev owned and operated websites (Devtodev.com and their subdomains); (ii) registrations as part of webinars, conference events, emails etc.; and (iii) any other product or activity that links to, or otherwise references, this privacy policy (collectively, “Analytics Platform“) and how Devtodev processes personal data it may receive as a result of its customers (“Customers”) use of the Devtodev mobile app analytics products and services (“Services”). We respect your privacy rights and value your trust. This Privacy Policy describes how we collect, receive, use, store, share, transfer, and process your personal information, as well as your rights in determining what we do with the information that we collect or hold about you.

1. INFORMATION WE COLLECT THROUGH OUR ANALYTICS PLATFORM

When using or interacting with our Analytics Platform, we may collect or receive the following types of information (collectively, “Information”).

“Personal Information” such as name, email, contact details or any other personal content that you provide to us whether through a form or field on our website or any other communication (e.g. email, phone, post etc.).
“Technical Information” such as browser type, operating system, device type, IP address and other similar technical information typically received from a browser or device automatically when visiting or interacting with our Analytics Platforms. This may include the referring URL that led you to our website.
“Usage Information” such as the pages you visited on our website, where you clicked, searches performed on our website and other similar information related to how you have used our website. It may also include information related to whether you receive, opened or clicked on any links in an email sent to you.

We understand that certain Technical information or Usage Information may, either alone or when combined with other data, be deemed personal data under various laws and jurisdictions and we are committed to treating such data in compliance with applicable laws.

2. INFORMATION WE MAY RECEIVE WHEN CUSTOMERS USE OUR SERVICES

When a Customer uses the Services, we may receive and process certain device, Technical and other Usage Information relating to Customers end users (“End Users”). Such information may vary from Customer to Customer depending on each Customer’s configuration of the Services and the specific events and engagement information the Customer chooses to collect but may include (collectively, “End User Data”)

“Device Information”: this refers to technical information related to an End User’s mobile device or computer, such as: device type and model, system language, OS type and version, rooted/jailbroken OS Flag, screen settings (resolution, PPI), app version, push token and time stamp and zone.
“Identifiers”: this refers to various identifiers that generally only identify a computer, device, browser or Application. For example, IP address (which may also provide general location information), User agent strings, Mobile Device Advertising Identifiers such as IDFA (identifier for advertisers) and Android ID (in Android devices); IDFV (ID for Vendors in iOS), Google Advertiser ID, Serial ID, Customer issued user ID and other similar identifiers including those generated by Devtodev to enable provision of the Services.
“Engagement Information”: this refers to information relating to End User actions within an app such as: session start, activity period, source of install, install date, last use date, links clicked, pages visited, in app purchases made and other payment-related player data (such as transaction ID, time and amount), progress within a game, cheater status flags, use of app functions and features including use of social networking links and other interactions, events and action Customers choose to measure and analyze within their Application (including advertising campaign related data – eg. advertising clicked or viewed, attribution data). For the specific privacy practices and data collected by an app using our Services please visit the app’s own privacy policy.

While End User Data does not generally contain any information that directly identifies an individual, such as names, addresses, credit cards or other similarly regulated financial information, health information, or any other type of sensitive personal information (“PII“), we acknowledge that under certain jurisdictions the End User Data we do receive when a Customer uses the Services may be deemed personal data and therefore, where applicable, will be treated as such. Within the scope of the engagement between Customers and Devtodev, Customers are contractually prohibited from collecting certain PII, unless otherwise agreed by Devtodev. However, Customers have sole control over their properties (including their applications) and configuration of the Services and thus Customers have the technical ability to configure the Services to collect PII. This includes, for example, a Customer using an End User’s email address as a Customer issued user ID Technical Identifier. If a Customer has configured the Services to collect PII then we may receive and process such data.

3. THE METHODS WE USE TO COLLECT AND RECEIVE INFORMATION FOR OUR ANALYTICS PLATFORM

Depending on the type of Information, we may collect or receive Information in the following ways:

When you voluntarily share Information with us. For example, when you register to one of our events, request that we contact you through our online forms, submit your CV, or when you request to receive certain content that we may make available (e.g., research and white papers).
Through use of cookies and other similar technologies (e.g., HTML5 Local Storage, LSO, web beacons, JavaScript, etc.). These technologies help us to analyze how our Analytics Platform are used and to tailor content that is relevant to you. It also helps us to deliver more relevant advertisements to you on our own or third-party sites. For more information on such technologies, including how to manage your cookie preferences, please see our Cookie Policy.
Information obtained from third-party sources. This includes Information received through the various business support tools and services that we use (e.g., Analytics platform, analytics services, etc.) and public sources such as social media sites. We may combine the Information received through these sources with other Information we have in order to ensure our records are up to date and so that we are able to provide you with relevant content.

You have choices in how we collect and use Information. See the “Your Choices” section below for more information.

4. HOW WE RECEIVE INFORMATION WHEN CUSTOMERS USE OUR SERVICES

Devtodev may offer its Customer various methods to send or otherwise upload data to to their accounts on Devtodev in order for Devtodev to provide Customers with the Services.

The main method used by Customers is through implementing the Devtodev SDK into the Customers mobile and Web app. The Devtodev SDK enables Customers to easily collect and direct certain information (as described in Section 2 above) to Devtodev for processing.

Other methods may include server to server where Customers send information directly from their servers to the Devtodev servers and granting access to Devtodev to certain Customer third-party sources.

5. THE PURPOSES

Analytics Platforms. We use Information received from our Analytics Platform for the following purposes:
1. To process your inquiries and to respond to your requests. For example, when you contact us to learn more about our products or services or when you request to receive certain materials from us (e.g. white papers, research papers, product and services information). Additionally, if you submit your CV to us, we use it to evaluate your candidacy (including by assessing your qualifications and skills). We process this Information in order to properly execute our obligations under the service agreements or pursuant to your consent, where we answer, consult, reply to your inquiries and requests when you initiate the first conversation.
2. To send you information related to our services and products that we believe may interest you, such as newsletters or product and service updates. Such communications will be sent to you when you have chosen to receive such communication or when we have a legitimate interest to market our products and services. In any event, you will always be able to opt-out of receiving such communications. Opting out may be done either directly in the communication received or through the ways described in the instructions in the “Your Choices” section below.
3. To understand how you have used our Analytics Platform and to customize them in accordance with your interests and past actions and choices. We do this based on our legitimate interest to operate our Analytics Platform, diagnose any problems with the Analytics Platform and to improve the Analytics Platform and your experience when navigating through them.
4. In our legitimate interest to prevent fraud or harm to us or to any third-party, and ensure the security of our network and services.
5. Where it is necessary for Devtodev to comply with its legal obligations and to exercise and enforce its legal rights.
6. We may use certain third-party marketing and advertising networks to help us market our products on our own website and on third-party websites (e.g. remarketing ads across the Internet by Google).
Services. We use Information received from our Services for the following purposes:
1. End User Personal Data. End User personal data we receive as a result of use of the Devtodev Services is only used to provide the Services to the Customers as further described in our agreements with the Customers. Devtodev does not use such End User personal data for its own purposes.
2. Customer Registration Information. With regards to personal data we may receive as a result of a Customer registering to the Services and/or their use of the Services (“Log Data”), we use such information to authenticate login to the Services, to communicate with the Customer and to process any payments in connection with the Services. Additionally, we may use: (i) registration information to inform Customers of any updates to the Services, including new features and functionalities; and (ii) Log Data to understand how Customers are using the Services so that we may efficiently audit, maintain and improve the Services provided to Customers.
3. Devtodev may use information derived from the aggregation of End User Data including with other data for research and analytics purposes and improvement and marketing of the Services (“Aggregated Data”). Aggregated Data shall be anonymous and in no way reveal the identity of the Customer or any End User.

6. WHO WE SHARE INFORMATION WITH

Analytics Platform. In order to conduct our business and operate our Analytics Platform, we may share Information with various third parties, such as:

Our subsidiary companies and global branches.
Third parties that help us operate our Analytics Platform (e.g., hosting company, recruitment platforms and agencies, payment processors, business management and email distribution service providers and other similar service providers). These companies are authorized to use your personal information only as necessary to provide these services to us.
When required by law, such as to comply with court orders, search warrants, regulatory orders, subpoenas, and other lawful requests by public authorities, including to meet national security or law enforcement requirements;
Legal authorities, consultants, advisors or service providers when required to investigate, respond to, or prevent, fraud; or when required to ensure the security of our network and services and protect the safety of Devtodev or the public.
As part of any merger or acquisition of Devtodev, Information may be transferred to the merging or acquiring company, as well as to any advisors representing a party during discussions of such merger or acquisition.
Devtodev resellers, agents, partners or service providers acting on our behalf in connection with the offering of Devtodev’s products or services.
Third-party marketing and advertising networks to help us market our products on our own website and on third-party websites (e.g. remarketing ads across the Internet by Google).

Without derogating from the foregoing, Devtodev may publish general aggregate and unidentifiable information (e.g. statistical information) relating to use of its Analytics Platform.

Please note that certain areas of the Devtodev Analytics Platform may enable you to share information with and communicate with other members of the Devtodev community. Your Personal Information may be disclosed to other members or in public areas when posting or otherwise engaging in such areas of the website. Please be sure you wish to share such information prior to posting or engaging in such areas.

Services. Devtodev does not share End User personal data it processes when Customers use the Services except in the following cases:

Upon our Customer’s request – (e.g. to third parties integrated with our Service);
To our subsidiaries and global branches as necessary to help us support and maintain the Services provided to Customers;
To our service providers who help to support our Services – such as data hosting providers and payment processors; Transfers to subsequent third parties are covered by the service agreements with our Customers. These companies are authorized to use personal data only as necessary to provide these services to us.
When legally required (e.g. court orders or other lawful requests by public authorities), including to meet national security or law enforcement requirements;
To respond to, or prevent, fraud or to protect the safety of Devtodev, its Customers, End Users or the public;
As part of any merger or acquisition of Devtodev, in which case End User Data may be transferred to the surviving or acquiring entity.

7. CROSS BORDER DATA TRANSFERS

We may need to transfer Information to countries where we and/or our service providers operate. Such countries may be different from the country in which the data originated and where data protection laws may not be equivalent to, or offer the same protection as, those in your country. By using our Analytics Platform and/or Services, you agree to any such transfers. In any event, where appropriate given the nature of services, we will put in place agreements with our service providers to ensure a level of privacy consistent with the terms of this Privacy Policy and applicable laws.
With regards to the collection, use, and retention of personal data transferred from the European Economic Area to the United States, please be assured that Devtodev continues to comply with all applicable laws in respect of such transfers and any data transfers to the United States will be governed by the Standard Contractual Clauses as set forth in our DPA with the relevant service provider.

8. PROTECTING YOUR INFORMATION

We have implemented appropriate technical and organizational measures based on industry standards. Such measures are designed to protect against unauthorized access or unlawful processing of Personal Information and against accidental loss, destruction or damage of Personal Information.

9. INFORMATION STORAGE AND RETENTION

We may store Information and End User Data on our own servers as well as those operated by third-party data hosting providers. As specified in Section 5 above (Cross Border Transfers), such servers may be located worldwide. Personal Information received from use of our Analytics Platform, or Registration Information will be stored for as long as necessary to pursue the purpose of the collection. Personal Information contained within End User Data is retained in accordance with the instructions of our Customers (e.g. for the period of time Customer uses the Services unless earlier deleted by the Customer) so please check the specific apps privacy policy for its retention policies. We may also retain your Personal Information for such time needed to pursue our legitimate business interests, in connection with any legal claims and compliance with legal obligations. When we use information for direct marketing purposes, we will retain your data until you opt-out from receiving the marketing materials; provided that we will need to retain certain information to maintain a record of your request.

10. MODIFICATIONS TO THIS POLICY

Devtodev may amend this Privacy Policy at any time, provided that in the event of a material change we shall provide notice on this page and/or a note near the link to this page. The updates shall apply immediately for new Information collected or provided as of the day of the update and following thirty (30) days for any Information collected or provided to Devtodev prior to the update date. If you do not agree to the terms of the new policy you are requested to cease using the Analytics Platform and contact us to pursue any of your rights We encourage you to periodically review this page for any updates.

11. YOUR CHOICES

We provide you with various choices on how we may use Information in connection with: (i) our marketing activities; and (ii) our use of cookies and similar technologies to serve your interest-based advertisements and to analyze usage of our Analytics Platform.

You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page, or you can contact us at info@devtodev.com. You can manage your preferences related to our use of cookies and similar technologies that we use, among other things, to provide you with targeted interest-based advertisements and to analyze your use of our Analytics Platform – please see our Cookie Policy for instructions. Additionally, certain advertisers (including Google) we work with may be members of NAI and/or the Digital Advertising Alliance. You may opt-out from such advertisers’ services here or at the following link: https://youradchoices.com/
In addition, the laws of some jurisdictions may provide you with various rights in connection with our processing of certain Information. Such rights may include:
1. The right to withdraw any previously provided consent;
2. The right to access certain information about you that we process;
3. The right to have us correct or update any personal data;
4. The right to have certain Information erased;
5. The right to have us temporarily block our processing of certain Information;
6. The right to have Information exported into common machine-readable format;
7. The right to object to our processing of Information in cases of direct marketing, or when we rely on legitimate interests as our lawful basis to process your information; and
8. The right to lodge a complaint with the appropriate data protection authority.

We will respond to your requests within a reasonable timeframe. Please note these rights may be limited in certain circumstances as provided by applicable law.

Please note that in respect of any End User personal data received as a result of Customer’s use of the Services, Devtodev is deemed as a data processor (as such terms is defined under the European Union General Data Protection Regulation) and End Users should contact our Customers to pursue any such legal data subject rights. Devtodev will cooperate with its Customers to support and comply with any such data subject rights requests.

For any additional information regarding such rights or to exercise any such rights please contact Devtodev at: info@devtodev.com.

12. SOCIAL MEDIA AND THIRD-PARTY SERVICES

Our website may offer a blog with ‘comments’ section and various social media features, such as a ‘share’ button or links to third-party websites and services, including Twitter, LinkedIn, Google+ and Facebook. When using any such features, certain information may be collected by such third parties, including your IP address or which page you are visiting on our website, and such third parties may set a cookie to enable the feature to function properly. Any data collected by such third parties is governed by such third-party’s privacy policy. You are encouraged to carefully review such third-party privacy policies.

13. CHILDREN’S PRIVACY

Devtodev does not knowingly collect or process personal data from or with respect to children under the age of 16, and you must be 16 years of age or older in order to establish an account for Devtodev’s Services. If you are a parent or legal guardian and believe that your child under the age of 16 has submitted his or her personal data or other data without your consent, permission, or authorization – please let us know immediately, and we will promptly act to remove your child’s data from our database, cease the use of such data and inform any other party we suspect to have access to such data to do the same.

14. CALIFORNIA PRIVACY RIGHTS

We may collect personal information about California residents who are afforded additional rights under the California Consumer Privacy Act, Cal. Civ. Code §§ 1798.100 et seq. (the “CCPA“). If you are a California resident, you can see more details about the types of personal information we have collected from you in the past 12 months and may collect from you in Section 1 above (Information We Collect) and how we collect such personal information in Section 3 above (The Methods We Use to Collect and Receive Information). The purposes for which we collect your personal information are further described in Section 5 above (The Purpose). We do not share your personal information with any third-party except as further described in Section 6 above (Who We Share Information With). Please refer to the other terms of this Privacy Policy to see further rights afforded to you and how we use your personal information.

We do not “Sell” (as defined in the CCPA) your personal information which we have collected or may collect and in the event we will Sell your personal information, we will notify you by updating this Privacy Policy in accordance with Section 10 above (Modifications to this Policy) and we will provide you with the option of opting out of such “sale”.

You, as a California resident, have certain rights regarding your personal information pursuant to the CCPA, subject to certain restrictions under applicable laws, including the rights to access your personal information, to delete your personal information, and to opt out of the “sale” of your personal data. You may request any of these by contacting us via email at info@devtodev.com or by physical mail to: Devtodev Ltd. (Attn: Legal Dept.) Sapir 1 St., Herzliya, Israel. Upon your request, we will verify that you are the person making this request and in order to do so, we may request identification documents from you.

15. CONTACTING US

If you have any questions or concerns about this Privacy Policy, the information we collect, the practices of Devtodev, or your dealings with the Analytics Platform, please contact us or our Data Protection Officer by sending an email to: info@devtodev.com or by physical mail to: Devtodev Ltd. (Attn: Legal Dept.) 14 Maskit St., Herzliya, Israel.