Notice at Collection and Privacy Policy

Effective Date: 26 July 2024
Last Revised/Reviewed: 26 July 2024

This Notice at Collection and Privacy Policy explains how Appinio GmbH and its applicable subsidiaries and affiliates ("Appinio", "Company", "us", "our", or "we") collect, use, disclose, sell, share, and/or retain personal information related to the AlphaPoll mobile application (the "App").

Certain states provide specific rights to their residents as listed below. While we will attempt to respond to a request from any U.S. resident, we reserve the right to deny requests if allowed under applicable law. Unless you are a California resident, any rights that may be available in your state are not afforded to you under this policy while you are operating in your commercial or employment capacity.

The information we collect through the App is primarily in our capacity as a service provider to our customers. As a result, we only collect, use, and disclose any information we collect as a service provider by following our agreements with our customers. This disclosure broadly describes the information we collect. But please note that we may not be able to process your request if it pertains to information we have collected on behalf of our customers, in which case you will need to submit your request directly to the relevant customer.

The terms used in this disclosure shall have the same or similar meaning as those terms in each of the applicable laws, or the closest approximation of such terms.

NOTICE AT COLLECTION

The following notice identifies the categories of personal information to be collected from you and the purposes for which the personal information will be used. We do not sell your personal information or use your personal information for online targeted advertising.

General Personal Information

Categories of Personal Information Purposes for Collection, Use, or Processing
Identifiers: For example, a name, address, online identifier, internet protocol ("IP") address, email address, payment information, or other similar identifiers.
  • To fulfill or meet the reason for which the information is provided, such as facilitating surveys through our mobile applications.
  • For our internal operational purposes
  • For auditing relating to consumer transactions including ad impressions and compliance with regulations.
  • Fraud and security detection.
  • Debugging to identify and repair errors.
  • Short-term data use for the current interaction that is not used to build a profile.
  • Servicing transactions and accounts (e.g., customer service, maintaining and servicing accounts, customer verification, payment processing) and providing our products and any additional services.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
  • Undertaking internal research for technological development and demonstration.
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
(Pursuant to California Law) Personal Information Categories from Cal. Civ. Code § 1798.80(e): For example, a name, address, and telephone number.
(Pursuant to California Law) Characteristics of CA or Federal Protected Classifications: For example, age (40 and over).
Commercial Information: For example, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or Other Similar Network Activity: For example, data on how consumers use the App.
Geolocation Data: For example, information that can be used to determine a device's physical location.

Sensitive Personal Information

Categories of Sensitive Personal Information Purposes for Collection, Use, or Processing
Account log-in
  • To perform services or provide goods you request and reasonably expect from us
  • To detect, prevent, and investigate security incidents involving your information
  • To investigate or curtail malicious, fraudulent, or illegal actions directed at us and to prosecute those responsible
  • To ensure the safety of you and others
  • To enhance your experience on our website in real time, so long as we do not disclose your information to a third party
  • To perform services for our business needs such as maintaining accounts, providing customer service, and fulfill orders
  • To ensure the quality or safety of a product, service, or device
  • To collect or process sensitive personal information where such information is not being used to infer characteristics about you but may be used to provide a specific good or service based on the sensitive information you provided
Racial or ethnic origin, or religious or philosophical beliefs
Health information, including mental or physical health diagnosis
Information concerning sex life, sexual orientation, and sexuality

Retention Periods

The period of time for which we retain information depends on the purposes for which we collect or use that information. We will delete or de-identify information when it is no longer needed to fulfill the purposes listed for each category above, unless a longer retention period is required to comply with applicable laws. There may be technical or other operational reasons where we are unable to fully delete or de-identify your information. Where this is the case, we will take reasonable measures to prevent further processing your information.

PRIVACY POLICY

The purpose of this policy is to provide you with a comprehensive description of our information practices with the App. You have certain rights to control the use of your personal information. This policy describes your rights as it relates to our information practices as to your personal information and how you can exercise those rights.

The following tables include the disclosures for the preceding 12 months of: categories of personal information we have collected about consumers, the categories we have disclosed for a business purpose, and categories of third parties with whom we shared the personal information during that period.

General Personal Information

Category Business or Commercial Purpose for Collection & Disclosure Categories of third parties to whom the information was disclosed
Identifiers
  • For our operational purposes or the operational purposes of our service provider or contractors
  • Keeping track of visitors to our website and mobile applications, and monitoring the effectiveness of our advertising, including auditing relating to counting ad impressions of unique visitors, verifying positioning and quality, and auditing compliance.
  • Ensuring security and integrity as needed and as reasonably necessary and proportionate for this purpose
  • Debugging to identify and repair errors that impair existing functionality
  • Short-term, transient use
  • Performing services on behalf of the business, including maintaining or servicing accounts, providing products or services, providing customer service, processing orders or transactions, verifying customer information, processing payments, providing financing, providing analytic services, storage, or other similar services.
  • Undertaking internal research for technological development.
  • Undertaking activities to verify or maintain quality or safety of a service or device and to improve or enhance a service or device.
  • Cloud storage and other hosting and development providers
  • Service provides to assist in ensuring the App functions properly
  • Communications providers (email, etc.)
  • Payment processors (limited to information for the purposes of processing payments)
  • Survey support providers
(Pursuant to California Law) Personal Information Categories from Cal. Civ. Code § 1798.80(e)
(Pursuant to California Law) Characteristics of California or Federal protected Classifications
Commercial Information
Internet or Other Similar Network Activity

Sensitive Personal Information

Unless otherwise allowed by applicable state law, we will only collect certain types of sensitive personal information with your consent. We do not use or disclose the below sensitive personal information for purposes other than those business purposes specifically enumerated under applicable state law, including California. As a result, we do not offer a right to limit our use or disclosure of these categories of sensitive personal information.

Category Business or Commercial Purpose for Collection & Disclosure Categories of third parties to whom the information was disclosed
Account log-in
  • To perform services or provide goods you request and reasonably expect from us
  • To detect, prevent, and investigate security incidents involving your information
  • To investigate or curtail malicious, fraudulent, or illegal actions directed at us and to prosecute those responsible
  • To ensure the safety of you and others
  • To enhance your experience on our website in real time, so long as we do not disclose your information to a third party
  • To perform services for our business needs such as maintaining accounts, providing customer service, and fulfill orders
  • To ensure the quality or safety of a product, service, or device
  • To collect or process sensitive personal information where such information is not being used to infer characteristics about you but may be used to provide a specific good or service based on the sensitive information you provided
  • Cloud storage and other hosting and development providers
  • Service provides to assist in ensuring the App functions properly
  • Communications providers (email, etc.)
  • Survey support providers
Health information, including mental or physical health diagnosis
Information concerning sex life, sexual orientation, and sexuality

The categories identified as collected in the tables above were collected directly from you through the App.

Selling/Targeting Advertising: We do not sell your personal information or use your personal information for online targeted advertising.

Your Right to Know

Certain states provide the right to request our disclosure of any of the following:

You can do this through a verified consumer request. That process is described below in the section, "How to Exercise Your Rights."

Your Right to Request Correction of Inaccurate Personal Information

Certain states provide you the right to request correction of inaccurate personal information maintained by us. We may request documentation from you to determine the accuracy of the information. If you provide us documentation either upon our request or through your own initiative, that documentation will only be used for the purpose of correcting your personal information and complying with our recordkeeping requirements.

As an alternative to correction, we may delete the inaccurate information if it does not negatively impact you or if you consent to this deletion. We reserve the right to deny this request if allowed under applicable law, or if we determine that the contested information is more likely than not accurate, based on the totality of circumstances. You can submit a correction request through a verified consumer request. That process is described below in the section, " How to Exercise Your Rights."

Your Right to Request Deletion of Your Personal Information

Certain states provide the right to request that we delete any of your personal information, subject to certain exceptions. You can do this through a verified consumer request. That process is described below in the section, "How to Exercise Your Rights."

There may be scenarios where we deny your deletion request. If that occurs, we will provide you with an explanation as to why we could not delete all or some of your personal information.

How to Exercise Your Rights

You may exercise your rights, as applicable, by submitting a verified consumer request to know information (and to receive your personal information in a portable format), to correct information, or for deletion.

The response to a request to know will provide the personal information we have collected and maintained about you, in a portable format, unless an exception under applicable state law applies. Please note that, depending on the applicable state law, we may not be required to provide personal information to you if you make multiple requests in a certain time period. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

You can exercise your right to access, correction, and deletion by contacting us through our online webform or email at privacy@appinio.com. We will ask that you provide certain personal information to confirm your identity and authenticate the request as identified in the webform. If you submit a request that is not through one of the above designated methods or is deficient in some manner unrelated to verification, we will provide you with information on how to submit the request or remedy any deficiencies with your request.

Once we receive your verifiable consumer request, we will promptly respond to your request as allowed under applicable law, if we are able to verify your identity.

Requests to Know or Delete for Child Under the Age of 13: We do not knowingly collect information of minors under the age of 13.

Using an Authorized Agent to Submit a Request

California:

Only you, or a natural person or a business entity registered with the Secretary of State to conduct business in California that you have authorized to act on your behalf, may make a verifiable consumer request related to your personal information, to opt-out of sale or sharing, or to limit the use or disclosure of your sensitive personal information. If you use an authorized agent, you may provide a power of attorney executed pursuant to California Probate Code sections 4000 to 4465. If a power of attorney that meets those provisions is not submitted, you will be required to provide the authorized agent signed permission to submit a request, verify your identity directly by submitting a verified consumer request according to the procedures in the section "How to Exercise Your Rights," and directly confirm with us that you provided the authorized agent permission to submit the request. To submit authorized agent documentation, contact us at privacy@appinio.com.

Other States:

If you use an authorized agent, you may provide a power of attorney executed pursuant to applicable state law. If a power of attorney is not submitted, you may be required to provide commercially reasonable identification of your identity and evidence of your authorized agent's authority to act on your behalf. For example, you may need to provide the authorized agent signed permission to submit a request, verify your identity directly by submitting a verified consumer request according to the procedures in the section "How to Exercise Your Rights," and directly confirm with us that you provided the authorized agent permission to submit the request, by contacting us at privacy@appinio.com.

Notice of Financial Incentive/Loyalty Program

We currently provide the following financial incentives:

The App allow you to participate in market research surveys by sharing your personal information with us, such as your answers and opinions, in response to our own surveys and/or our customers' surveys and/or third-party surveys ("Surveys"). The App may also allow you to participate in other evaluation opportunities and provide feedback, including, without limitation, watching third-party advertisements, installing third-party apps, and/or performing other actions (e.g., making referrals) (collectively, "Other Opportunities" and, together with Surveys, the "Marketing Engagements"). In return for participating in the Marketing Engagements, you will receive the applicable rewards specified in the App for the specific Marketing Engagement, which may include, but not be limited to, monetary compensation through a gift card or direct payment through an electronic payment processor (e.g., PayPal or Visa or the like), or may include experience points (levels), and "Appinio Coins" or other benefits that we add to the App from time to time that, which you can redeem within the App ("Rewards"). Your participation in these Surveys provides us and our customers valuable information in support of our business and the products and services our customers may offer. You are free to opt-out of the Surveys at any time through the App.

Your Right to Non-Discrimination for the Exercise of a Privacy Right

We will not discriminate against you for exercising any of your state privacy rights. However, we may still offer you certain financial incentives permitted under applicable state law, such as, rewards, premium features, loyalty accounts that can result in different quality levels.

Supplemental U.S. State Privacy Rights

In addition to the privacy rights listed above, certain states provide supplemental privacy rights to residents of those states.

Right to Opt-Out of Certain Profiling

We do not engage in any profiling.

Right to Appeal

You have the right to appeal our refusal to take action on, or respond to, a verified consumer request. Upon receipt of our denial or refusal to take action on, or to respond to, a verified consumer request, a consumer has 90 days to submit a request to appeal our decision by email. We will timely inform you in writing of any action taken or not taken in response. We will also include a written explanation of the reasons for our decision.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact for More Information

If you have any questions or comments about this notice, the ways in which we collect and use your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: privacy@appinio.com.

Postal Address: Loockerman Street, STE 202-828, Dover, DE, 19901