About End-Users (“End-Users,” “you,” “your”) of our owned and operated mobile applications (“apps”) and third-party mobile apps that use our Ad Services (see Section 1 for more information on our “Ad Services”) either through a Software Development Kit (“SDK”) or other collection interfaces (“APIs,” “VAST Tags”); About individuals who visit and engage with our (i) corporate website at www.SAPPOC.co and other properties, be it on our (ii) official social media pages and (iii) email marketing, (iv) website subscriptions, and (v) other sales and marketing activities (collectively, SAPPOC Properties”).
SAPPOC provides mobile advertising automation technology and solutions to advertisers, buyers, app developers, and publishers of mobile apps and websites (collectively, “Clients”). This is done by providing our clients —and through them, their customers — with tools to deliver relevant online advertising to End-Users through our Ad Services, which include our ad exchange (SAPPOC Exchange”), advertising platform (SAPPOC Entregar”), and app publishing arm (SAPPOC Studios”). More information on these tools can be found in section 3 labeled “Cookies and Similar Tracking Technologies.”
In line with our commitment to market quality and transparency, SAPPOC may also share certain relevant information about End-Users collected through our Ad Services with clients and other third parties for data validation, fraud protection, and marketing purposes
While using our Ad Services, we may (but do not necessarily, or always) collect a variety of information from the End-User. However, our properties are designed to process information in such a manner that the information cannot be directly attributed to a specific, identifiable individual without the use of additional information (such as name, address, or email address). Below are some of the information we collect in relation to our Ad Services:
We use the information we collect for a variety of business purposes, including:
SAPPOC, our Clients, and our third-party partners collect and use information about End-Users through cookies and other tracking technologies on SAPPOC Properties. Below, we detail the technologies we use and how each is utilized. End-Users may opt-out by following the opt-out process detailed in Section 5.2.
We use a combination of the following tracking technologies to help us collect information:
We use these tracking technologies to collect information automatically from End-Users’ devices. They help us identify unique browsers or devices used by an End-User and to perform functions like limiting the same ad from continuously reappearing, ensuring that ads are properly displayed on our publishers’ apps and websites, and serving relevant ads to the End-User.
Further on, our Clients may use information that we share with them to establish connections among related devices (such as smartphones, tablets, and computers) for targeted advertising, analytics, and reporting purposes. They may match an End User’s devices if the End User logs into the same online service on multiple devices or web browsers, or if the End User’s devices share similar attributes that support an inference that they are used by the same person or household. This means that information about an End User’s use of websites or applications on his or her current browser or device may be combined and used with information from the End User’s other browsers or devices. For example, this allows Media Buyers to deliver ads on an End User’s tablet-based on activities the End User engaged in on his or her smartphone. To opt-out of cross-device targeting practices, please follow the instructions in the section below.
While using SAPPOC Properties, visitors may be asked to voluntarily provide personal information. This might occur when visitors register for an SAPPOC account, subscribe to our mailing list, fill out a lead generation form on social media, or contact us via our website. Often, the information we collect include contact details (name, email, phone number), personal information (company, job title, office location), messages detailing the nature of communication, and any attachments visitors may include in relation to this.
The information we collect on SAPPOC Properties may be used for:
The information we collect is generally shared in relation to the use of SAPPOC Ad Services. Below, we detail some instances when information is shared:
As Requested by the End-User. Lastly, we may disclose an individual’s information to any other person with the individual’s consent to such disclosure.
In connection with the GDPR, CCPA, and other relevant Privacy Laws, the SAPPOC Opt-Out process describes the steps you need to take to request the deletion or pull-out of data being used by our platform for internet-based advertising and cross-device targeting purposes.
You can opt-out by clicking the button below:
Please take note that this opt-out option is cookie-based. So if you change 0or update your browser, delete cookies, or switch to another device, you will have to repeat the process and opt-out again. Lastly, if your browser is using third-party cookie blockers, it may cause our opt-out option button to not work properly.
If you would like to opt-out of one of our Clients’ properties, you may check the opt-out process detailed in their site. You can usually find this information on their Privacy Policies or Web Opt-Out Policies.
End-Users who would like to opt-out or receiving advertising from our Clients on our own apps and partner apps, can do the following:
Take note that the steps above are subject to possible changes made by the above platforms. If your device does not fall under the above categories, please check your device’s settings.
If you would like to opt-out of receiving promotional messages from SAPPOC via direct email marketing, click the “Unsubscribe” button located at the bottom of the email. Otherwise, you may contact us here. If you are one of our Clients, however, you may still receive emails from us that are relevant to our business relationship.
This Policy is limited to SAPPOC Properties and Ad Services. It does not cover, unless otherwise stated in this Policy, the privacy and information-collection practices of other third-parties, including our Clients or partners that use or link to our Properties and Ad Services.
When using our website, apps, and other properties, you may be directed to other websites, apps, and properties. This does not signify an endorsement on our part. SAPPOC is not responsible for third party privacy and information-collection practices. Moreover, this policy does not cover the collection, usage, and disclosure of information by other organizations, such as Facebook, Twitter, LinkedIn, and Google, where SAPPOC may also have social media pages. We encourage you to read and review third-party policies and terms and conditions and use third-party services at your own discretion.
SAPPOC End-Users have the right to request access to, change, update, or delete personal information as required. According to applicable laws, a small fee to access and disclose this personal information may be charged, but End-Users will be informed beforehand should this be the case.
Moreover, End-Users can withdraw consent allowing us to collect and process personal information at any time. Doing so will not affect the lawfulness of any data processing we may have done before the consent is withdrawn or impact any processing done within the bounds of applicable laws that previously depended on that consent.
European Economic Area (EEA) residents also have the right to (i) object to the processing or request portability of their personal information and (ii) complain to a data protection authority about SAPPOC’s collection and use of personal information. To exercise the right to object, email us at legal@SAPPOC.co. For more information about making a complaint, contact your local data protection authority via the information listed here.
We will retain personal information for the period necessary to fulfill the purposes outlined in this Policy and where we have ongoing legitimate business needs to do so (for example, to provide the Ad Services, to comply with applicable legal, tax or accounting requirements, to enforce our agreements or comply with our legal obligations) unless a longer retention period is required or permitted by law. We retain the information collected from SAPPOC Websites and SAPPOC Ad Services for as long as necessary to achieve our objectives as detailed in this Policy, and to comply with our legal obligations, resolve disputes, and enforce our agreements.
Residents of the European Economic Area (EAA), Switzerland, or the United Kingdom may obtain a copy of your personal information or request for an amendment or correction of such information by contacting us at legal@SAPPOC.co. More information can be found on Section 6.
We use reasonable organizational, technical, administrative, and physical safeguards to protect the personal information we collect and process. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information and to help ensure that your data is safe and secure. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. If you have reason to believe that your data is at risk, please immediately notify us of the problem by contacting us here or emailing legal@SAPPOC.co.
SAPPOC is a global media and technology company. As such, we have offices located in multiple countries and also work with other global companies and technologies. Thus, this requires us to transfer your personal data outside the country where it was first provided. Moreover, SAPPOC Properties and Ad Services are hosted in both the United States and Singapore. Your data may be transferred to, stored, and processed by us in our facilities and our partners in locations where data protection laws may differ from the laws of your country of residence.
With that in mind, we have safeguards in place in accordance to relevant laws to protect your personal data. These include (i) requiring all group companies to protect personal data being processed in accordance with EU data protection laws by implementing the European Commission’s Standard Contract Clauses for transfers of personal information between group companies, and adhering to the Privacy Shield Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement with regard to personal data.
The legal grounds for SAPPOC to process the Personal Information detailed above for the purposes covered in this policy are explained below:
When Personal Information is transferred outside of the EEA, Switzerland, or the UK, SAPPOC will put in place appropriate safeguards to ensure it’s protected. Moreover, your Personal Information will only be transferred to countries outside EU/EEA as permitted by applicable laws, such as based on your consent, based on the adequacy decisions of the European Commission, and by contractual regulations such as the EU Standard Data Protection Clauses. More information of how we handle International Data Transfers can be found in Section 5.7.
Under the GDPR, you are provided with rights with regard to the Personal Information we hold about you. These include the right to access data, to correct data, to object to its processing or withdraw consent, the right to erasure, and finally, the right to lodge complaints. More information can be found in Section 5.4 RIGHT TO PROTECT YOUR DATA.
In compliance with the California Consumer Privacy Act (“CCPA”), California residents have the right to request SAPPOC to disclose information we have collected about them. Moreover, they have the right to ask us to delete that information and opt-out of the sale of that information, subject to certain restrictions.
In addition, Personal Information may be collected as part of SAPPOC’s Ad Services as a “Service Provider,” defined in the instructions provided by Customers considered as Businesses under the CCPA. In case an End-User would like to exercise their rights under the CCPA, they are advised to contact the relevant Customer. Meanwhile, SAPPOC is dedicated towards assisting its Customers’ businesses in fulfilling Consumers’ rights.
In case the publishers and mobile app developers we work with request for the deletion of any End User’s Personal Information that have been collected and retained as part the services provided to them, SAPPOC will promptly do so on our Clients behalf, unless retaining the aforementioned information is necessary. Some of these instances include completing existing transactions with users, detecting security incidents, identifying and repairing errors, exercising free speech or another right provided by law, complying with specific laws or legal obligations, or any other internal and lawful uses.
We will review and update this Policy to reflect changes to our privacy practices and will note the date of its most recent revision at the top of this Policy. Please check our Policy regularly to ensure you have read the latest version and to stay informed of our privacy practices. We encourage you to review this Policy frequently to be informed of how SAPPOC is protecting your information.