PRIVACY POLICY

We also obtain data from third parties. We protect data obtained from third parties according to the practices described in this statement, plus any additional restrictions imposed by the source of the data. These third-party sources vary over time and include:

• Data brokers from which we purchase demographic data to supplement the data we collect.
• Services that make user-generated content from their service available to others, such as local business reviews or public social media posts.
• Communication services, including email providers and social networks, when you give us permission to access your data on such third-party services or networks.
• Service providers that help us determine your device’s location.
• Partners with which we offer co-branded services or engage in joint marketing activities.
• Developers who create experiences for Apptitude products and software.
• Publicly-available sources, such as open government databases.

If you represent an organization, such as a business or school, that utilizes Enterprise Products from Apptitude, please see the Enterprise products section of this privacy statement to learn how we process your data.

You have choices when it comes to the technology you use and the data you share. When you are asked to provide personal data, you can decline. Many of our products require some personal data to operate and provide you with a service. If you choose not to provide data necessary to operate and provide you with a product or feature, you cannot use that product or feature. Likewise, where we need to collect personal data by law or to enter into or carry out a contract with you, and you do not provide the data, we will not be able to enter into the contract; or if this relates to an existing product you’re using, we may have to suspend or cancel it. We will notify you if this is the case at the time. Where providing the data is optional, and you choose not to share personal data, features like personalization that use the data will not work for you.

The data we collect depends on the context of your interactions with Apptitude and the choices you make (including your privacy settings), the products and features you use, your location, and applicable law.

The data we collect can include the following:

Name and contact data. Your first and last name, email address, postal address, phone number, and other similar contact data.

Credentials. Passwords, password hints, and similar security information used for authentication and account access.

Demographic data. Data about you such as your age, gender, country, and preferred language.

Payment data. Data to process payments, such as your payment instrument number (such as a credit card number) and the security code associated with your payment instrument.

Subscription and licensing data. Information about your subscriptions, licenses, and other entitlements.

Interactions. Data about your use of Apptitude products. In some cases, such as search queries, this is data you provide in order to make use of the products. In other cases, such as error reports, this is data we generate. Other examples of interactions data include:

Device and usage data. Data about your device and the product and features you use, including information about your hardware and software, how our products perform, as well as your settings.For example:

• Payment and account history. Data about the items you purchase and activities associated with your account.
• Browse history. Data about the webpages you visit.
• Device, connectivity, and configuration data. Data about your device, your device configuration, and nearby networks. For example, data about the operating systems and other software installed on your device, including product keys. In addition, IP address, device identifiers (such as the IMEI number for phones), regional and language settings, and information about WLAN access points near your device.
• Error reports and performance data. Data about the performance of the products and any problems you experience, including error reports. Error reports (sometimes called “crash dumps”) can include details of the software or hardware related to an error, contents of files opened when an error occurred, and data about other software on your device.
• Troubleshooting and help data. Data you provide when you contact Apptitude for help, such as the products you use, and other details that help us provide support. For example, contact or authentication data, the content of your chats and other communications with Apptitude, data about the condition of your device, and the products you use related to your help inquiry. When you contact us, such as for customer support, phone conversations or chat sessions with our representatives may be monitored and recorded.
• Interests and favorites. Data about your interests and favorites, such as the sports teams you follow, the programming languages you prefer, the stocks you track, or cities you add to track things like weather or traffic. In addition to those you explicitly provide, your interests and favorites can also be inferred or derived from other data we collect.
• Content consumption data. Information about media content (e.g., TV, video, music, audio, text books, apps, and games) you access through our products.
• Searches and commands. Search queries and commands when you use Apptitude products with search or related productivity functionality.
• Voice data. Your voice data, such as the search queries or commands you speak, which may include background sounds.
• Images. Images and related information, such as picture metadata. For example, we collect the image you provide when you use a search image-enabled service.
• Contacts and relationships. Data about your contacts and relationships if you use a product to share information with others, manage contacts, communicate with others, or improve your productivity.
• Social data. Information about your relationships and interactions between you, other people, and organizations, such as types of engagement (e.g., likes, dislikes, events, etc.) related to people and organizations.
• Location data. Data about your device’s location, which can be either precise or imprecise. For example, we collect location data using Global Navigation Satellite System (GNSS) (e.g., GPS) and data about nearby cell towers and Wi-Fi hotspots. Location can also be inferred from a device’s IP address or data in your account profile that indicates where it is located with less precision, such as at a city or postal code level.

Other content we collect when providing products to you include:

Communications, including audio, video, text (typed, dictated, or otherwise), in a message, email, call, meeting request, or chat.
Photos, images, songs, movies, software, and other media or documents you store, retrieve, or otherwise process with our cloud.
Video or recordings. Recordings of events and activities at Apptitude buildings, and other locations. If you enter Apptitude locations or attend a Apptitude event that is recorded, we may process your image and voice data.

Feedback and ratings. Information you provide to us and the content of messages you send to us, such as feedback, survey data, and product reviews you write.

Product-specific sections below describe data collection practices applicable to use of those products.

We also use the data to operate our business, which includes analyzing our performance, meeting our legal obligations, developing our workforce, and doing research.

For these purposes, we combine data we collect from different contexts (for example, from your use of two Apptitude products). However, we have built in technological and procedural safeguards designed to prevent certain data combinations where required by law. For example, where required by law, we store data we collect from you when you are unauthenticated (not signed in) separately from any account information that directly identifies you, such as your name, email address, or phone number.

When we process personal data about you, we do so with your consent and/or as necessary to provide the products you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests of Apptitude as described in this section and in the Reasons we share personal data section of this privacy statement. When we transfer personal data from the European Economic Area, we do so based on a variety of legal mechanisms, as described in the Where we store and process personal data section of this privacy statement.

More on the purposes of processing:

Provide our products. We use data to operate our products and provide you with rich, interactive experiences. Or, for example, if you enter a search query in the search engines we provide, we send that query to one of our third-party provider to display search results to you. Additionally, as communications are a feature of various products, programs, and activities, we use data to contact you. For example, we may contact you by phone or email or other means to inform you when a subscription is ending or discuss your licensing account. We also communicate with you to secure our products, for example by letting you know when product updates are available.
Product improvement. We use data to continually improve our products, including adding new features or capabilities. For example, we use error reports to improve security features.
Personalization. Many products include personalized features, such as recommendations that enhance your productivity and enjoyment. These features use automated processes to tailor your product experiences based on the data we have about you, such as inferences we make about you and your use of the product, activities, interests, and location. If you have a Apptitude account, with your permission, we can sync your settings on several devices. Many of our products provide controls to disable personalized features.
Product activation. We use data—such as device and application type, location, and unique device, application, network, and subscription identifiers—to activate products that require activation.
Product development. We use data to develop new products. For example, we use data, often de-identified, to better understand our customers’ computing and productivity needs which can shape the development of new products.
Customer support. We use data to troubleshoot and diagnose product problems, repair customers’ devices, and provide other customer care and support services.
Help secure and troubleshoot. We use data to help secure and troubleshoot our products. This includes using data to protect the security and safety of our products and customers, detecting malware and malicious activities, troubleshooting performance and compatibility issues to help customers get the most out of their experiences, and notifying customers of updates to our products. This may include using automated systems to detect security and safety issues.
Safety. We use data to protect the safety of our products and our customers. Our security features and products can disrupt the operation of malicious software and notify users if malicious software is found on their devices. For example, some of our products, such as Browser Extensions, Browsers or other applications, can systematically scan content in an automated manner to identify suspected spam, viruses, abusive actions, or URLs that have been flagged as fraud, phishing, or malware links; and we reserve the right to block delivery of a communication or remove content if it violates our terms.
Updates. We use data we collect to develop product updates and security patches. For example, we may use information about your device’s capabilities, such as available memory, to provide you a software update or security patch. Updates and patches are intended to maximize your experience with our products, help you protect the privacy and security of your data, provide new features, and ensure your device is ready to process such updates.
Promotional communications. We use data we collect to deliver promotional communications. You can sign up for email subscriptions and choose whether you wish to receive promotional communications from Apptitude by email, SMS, physical mail, and telephone. For information about managing your contact data, email subscriptions, and promotional communications, see the How to access and control your personal data section of this privacy statement.
Relevant offers. Apptitude uses data to provide you with relevant and valuable information regarding our products. We analyze data from a variety of sources to predict the information that will be most interesting and relevant to you and deliver such information to you in a variety of ways. For example, we may predict your interest in gaming and communicate with you about new games you may like.
Advertising. Apptitude does not use what you say in email, chat, video calls, or voice mail, or your documents, photos, or other personal files to target ads to you. We use data we collect through our interactions with you, through some of our products, and on third-party web properties, for advertising in our products and on third-party properties. We may use automated processes to help make advertising more relevant to you. For more information about how your data is used for advertising, see the Advertising section of this privacy statement.
Reporting and business operations. We use data to analyze our operations and perform business intelligence. This enables us to make informed decisions and report on the performance of our business.
Protecting rights and property. We use data to detect and prevent fraud, resolve disputes, enforce agreements, and protect our property. For example, we use data to confirm the validity of software licenses to reduce piracy. We may use automated processes to detect and prevent activities that violate our rights and the rights of others, such as fraud.
Legal compliance. We process data to comply with law. For example, we use the age of our customers to ensure we meet our obligations to protect children’s privacy. We also process contact information and credentials to help customers exercise their data protection rights.
Research. With appropriate technical and organizational measures to safeguard individuals’ rights and freedoms, we use data to conduct research, including for public interest and scientific purposes.

In addition, we share personal data among Apptitude-controlled affiliates and subsidiaries. We also share personal data with vendors or agents working on our behalf for the purposes described in this statement. For example, companies we’ve hired to provide customer service support or assist in protecting and securing our systems and services may need access to personal data to provide those functions. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose. We may also disclose personal data as part of a corporate transaction such as a merger or sale of assets.

Finally, we will retain, access, transfer, disclose, and preserve personal data, including your content, when we have a good faith belief that doing so is necessary to do any of the following:

• Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies.
• Protect our customers, for example, to prevent spam or attempts to defraud users of our products, or to help prevent the loss of life or serious injury of anyone.
• Operate and maintain the security of our products, including to prevent or stop an attack on our computer systems or networks.
• Protect the rights or property of Apptitude, including enforcing the terms governing the use of the services—however, if we receive information indicating that someone is using our services to traffic in stolen intellectual or physical property of Apptitude, we will not inspect a customer’s private content ourselves, but we may refer the matter to law enforcement.

For more information about data we disclose in response to requests from law enforcement and other government agencies, please see our Law Enforcement Requests Report.

Please note that some of our products include links to products of third parties whose privacy practices differ from those of Apptitude. If you provide personal data to any of those products, your data is governed by their privacy policies.

• If Apptitude obtained your consent to use your personal data, you can withdraw that consent at any time.
• You can request access to, erasure of, and updates to your personal data.
• If you’d like to port your data elsewhere, you can use tools Apptitude provides to do so, or if none are available, you can contact Apptitude for assistance.

You can also object to or restrict the use of your personal data by Apptitude. For example, you can object at any time to our use of your personal data:

• For direct marketing purposes.
• Where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party.

You may have these rights under applicable laws, including the EU General Data Protection Regulation (GDPR), but we offer them regardless of your location. In some cases, your ability to access or control your personal data will be limited, as required or permitted by applicable law.

If your organization, such as your employer, school, or service provider, provides you with access to and is administering your use of Apptitude products, contact your organization to learn more about how to access and control your personal data.

You can access and control your personal data that Apptitude has obtained, and exercise your data protection rights, using various tools we provide. The tools most useful to you will depend on our interactions with you and your use of our products. Here is a general list of tools we provide to help you control your personal data; specific products may provide additional controls.

Not all personal data processed by Apptitude can be accessed or controlled via the tools above. If you want to access or control personal data processed by Apptitude that is not available via the tools above or directly through the Apptitude products you use, you can always contact Apptitude at the address in the How to contact us section or by using our web form. We will respond to requests to control your personal data within 30 days.

Your communications preferences

You can choose whether you wish to receive promotional communications from Apptitude by email, SMS, physical mail, and telephone. If you receive promotional email or SMS messages from us and would like to opt out, you can do so by following the directions in that message. You can also make choices about the receipt of promotional email, telephone calls, and postal mail by signing in with your personal Apptitude account, and viewing your communication permissions where you can update contact information, manage Apptitude-wide contact preferences, opt out of email subscriptions, and choose whether to share your contact information with Apptitude partners. If you do not have a personal Apptitude account, you can manage your Apptitude email contact preferences by using this web form. These choices do not apply to mandatory service communications that are part of certain Apptitude products, programs, activities, or to surveys or other informational communications that have their own unsubscribe method.

Your advertising choices

To opt out of receiving interest-based advertising from Apptitude, visit our opt-out page. When you opt out, your preference is stored in a cookie that is specific to the web browser you are using. The opt-out cookie has an expiration date of five years. If you delete the cookies on your device, you need to opt out again.

For Apptitude-controlled advertising that appears in apps or software we produce, you may use the opt-out linked to your personal Apptitude account, or opt out of interest-based advertising by turning off the advertising ID in software settings.

Because the data used for interest-based advertising is also used for other necessary purposes (including providing our products, analytics, and fraud detection), opting out of interest-based advertising does not stop that data collection. You will continue to get ads, although they may be less relevant to you.

You can opt out of receiving interest-based advertising from third parties we partner with by visiting their sites (see above).

Browser-based controls

When you use a browser, you can control your personal data using certain features. For example:

• Cookie controls. You can control the data stored by cookies and withdraw consent to cookies by using the browser-based cookie controls described in the Cookies section of this privacy statement.
• Tracking protection. You can control the data third-party sites can collect about you, by blocking third-party content, including cookies, from any site that you add in the browser settings to be blocked.
• Browser controls for “Do Not Track.” Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the DNT signal, Apptitude services do not currently respond to browser DNT signals. We continue to work with the online industry to define a common understanding of how to treat DNT signals. In the meantime, you can use the range of other tools we provide to control data collection and use, including the ability to opt out of receiving interest-based advertising from Apptitude as described above.

Apptitude uses cookies and similar technologies for several purposes, depending on the context or product, including:

Storing your preferences and settings. We use cookies to store your preferences and settings on your device, and to enhance your experiences. For example, if you enter your city or postal code to get local news or weather information on a Apptitude website, depending on your settings, we store that data in a cookie so that you will see the relevant local information when you return to the site. Saving your preferences with cookies, such as your preferred language, prevents you from having to set your preferences repeatedly. If you opt out of interest-based advertising, we store your opt-out preference in a cookie on your device.
Sign-in and authentication. We use cookies to authenticate you. When you sign in to a website using your personal Apptitude account, we store a unique ID number, and the time you signed in, in an encrypted cookie on your device. This cookie allows you to move from page to page within the site without having to sign in again on each page. You can also save your sign-in information so you do not have to sign in each time you return to the site.
Security. We use cookies to process information that helps us secure our products, as well as detect fraud and abuse.
Storing information you provide to a website. We use cookies to remember information you shared. When you provide information to Apptitude, such as when you add products to a shopping cart on Apptitude websites, we store the data in a cookie for the purpose of remembering the information.
Social media. Some of our websites include social media cookies, including those that enable users who are signed in to the social media service to share content via that service.
Feedback. Apptitude uses cookies to enable you to provide feedback on a website.
Interest-based advertising. Apptitude uses cookies to collect data about your online activity and identify your interests so that we can provide advertising that is most relevant to you. You can opt out of receiving interest-based advertising from Apptitude as described in the How to access and control your personal data section of this privacy statement.
Showing advertising. Apptitude uses cookies to record how many visitors have clicked on an advertisement and to record which advertisements you have seen, for example, so you don’t see the same one repeatedly.
Analytics. We use first- and third-party cookies and other identifiers to gather usage and performance data. For example, we use cookies to count the number of unique visitors to a web page or service and to develop other statistics about the operations of our products.
Performance. Apptitude uses cookies to understand and improve how our products perform. For example, we use cookies to gather data that helps with load balancing; this helps ensure that our websites remain up and running.

Some of the cookies we commonly use are listed below. This list is not exhaustive, but it is intended to illustrate the primary purposes for which we typically set cookies. If you visit one of our websites, the site will set some or all of the following cookies:

UID, AC, and APPPC. Identifies unique web browsers visiting Apptitude sites. These cookies are used for advertising, site analytics, and other operational purposes.
ANON. Contains the ANID, a unique identifier derived from your Apptitude account, which is used for advertising, personalization, and operational purposes. It is also used to preserve your choice to opt out of interest-based advertising from Apptitude if you have chosen to associate the opt-out with your Apptitude account.
CC. Contains a country code as determined from your IP address.
PPAuth, APPAuth. Helps to authenticate you when you sign in with your Apptitude account.
AC0. Detects whether cookies are enabled in the browser.
AS0. Identifies a specific session.
NAP. Contains an encrypted version of your country, postal code, age, gender, language and occupation, if known, based on your Apptitude account profile.
AH. Appears on co-branded sites where Apptitude is partnering with an advertiser. This cookie identifies the advertiser, so the right ad is selected.
childinfo, kcdob, kcrelid, kcru, pcfm. Contains information that Apptitude account uses within its pages in relation to child accounts.
AR. Used to collect information for analytics purposes.
ATOptOut. Records your decision not to receive interest-based advertising delivered by Apptitude.

In addition to the cookies Apptitude sets when you visit our websites, third parties can also set cookies when you visit Apptitude sites. For example:

• Companies we hire to provide services on our behalf, such as site analytics, place cookies when you visit our sites. See opt-out links below.
• Companies that deliver content, such as videos or news, or ads on Apptitude sites, place cookies on their own. These companies use the data they process in accordance with their privacy policies, which may enable these companies to collect and combine information about your activities across websites, apps, or online services.

How to control cookies

Most web browsers automatically accept cookies but provide controls that allow you to block or delete them. For example, in Apptitude browsers, you can block or delete cookies by browsing to Settings > Privacy section. Please refer to your browser’s privacy or help documentation to find Instructions for blocking or deleting cookies in other browsers.

Certain features of Apptitude products depend on cookies. If you choose to block cookies, you cannot sign in or use some of those features, and preferences that are dependent on cookies will be lost. If you choose to delete cookies, any settings and preferences controlled by those cookies, including advertising preferences, are deleted and will need to be recreated.

Our use of web beacons and analytics services

Some Apptitude webpages contain electronic tags known as web beacons that we use to help deliver cookies on our websites, count users who have visited those websites, and deliver co-branded products. We also include web beacons or similar technologies in our electronic communications to determine whether you open and act on them.

In addition to placing web beacons on our own websites, we sometimes work with other companies to place our web beacons on their websites or in their advertisements. This helps us develop statistics on how often clicking on an advertisement on a Apptitude website results in a purchase or other action on the advertiser’s website.

Finally, Apptitude products often contain web beacons or similar technologies from third-party analytics providers, which help us compile aggregated statistics about the effectiveness of our promotional campaigns or other operations. These technologies enable the analytics providers to set or read their own cookies or other identifiers on your device, through which they can collect information about your online activities across applications, websites, or other products. However, we prohibit these analytics providers from using web beacons on our sites to collect or access information that directly identifies you (such as your name or email address). You can opt out of data collection or use by some of these analytics providers by clicking any of the following links: Adjust, AppsFlyer, Clicktale, Flurry Analytics, Google Analytics (requires you to install a browser add-on), Kissmetrics, Mixpanel, Nielsen, Visible Measures, or WebTrends.

Other similar technologies

In addition to standard cookies and web beacons, our products can also use other similar technologies to store and read data files on your computer. This is typically done to maintain your preferences or to improve speed and performance by storing certain files locally. But, like standard cookies, these technologies can also store a unique identifier for your computer, which can then track behavior.

Local Shared Objects or “Flash cookies.” Websites that use Adobe Flash technologies can use Local Shared Objects or “Flash cookies” to store data on your computer. To learn how to manage or block Flash cookies, go to the Flash Player help page.

• Creating your Apptitude account. When you create a personal Apptitude account, you will be asked to provide certain personal data and we will assign a unique ID number to identify your account and associated information. While some products, such as those involving payment, require a real name, you can sign in to and use other Apptitude products without providing your real name. Some data you provide, such as your display name, email address, and phone number, can be used to help others find and connect with you within Apptitude products. For example, people who know your display name, email address, or phone number can use it to search for you on Appritude messengers or email and send you an invite to connect with them. Note that if you use a work email address to create a personal Apptitude account, your employer may gain access to your data. In some cases, you will need to change the email address to a personal email address in order to continue accessing consumer-oriented products.
• Signing in to Apptitude account. When you sign in to your Apptitude account, we create a record of your sign-in, which includes the date and time, information about the product you signed in to, your sign-in name, the unique number assigned to your account, a unique identifier assigned to your device, your IP address, and your operating system and browser version.
• Signing in to Apptitude products or services. Signing in to your account enables improved personalization, provides seamless and consistent experiences across products and devices, permits you to access and use cloud data storage, allows you to make payments using payment instruments stored in your Apptitude account, and enables other enhanced features and settings. When you sign in to your account, you will stay signed in until you sign out. When you are signed in, some products will display your name or username and your profile photo (if you have added one to your profile) as part of your use of Apptitude products, including in your communications, social interactions, and public posts.
• Signing in to third-party products. If you sign in to a third-party product with your Apptitude account, you will share data with the third party in accordance with the third party’s privacy policy. The third party will also receive the version number assigned to your account (a new version number is assigned each time you change your sign-in data); and information that describes whether your account has been deactivated. If you share your profile data, the third party can display your name or user name and your profile photo (if you have added one to your profile) when you are signed in to that third-party product. If you chose to make payments to third-party merchants using your Apptitude account, Apptitude will pass information stored in your Apptitude account to the third party or its vendors (e.g., payment processors) as necessary to process your payment and fulfill your order (such as name, credit card number, billing and shipping addresses, and relevant contact information). The third party can use or share the data it receives when you sign in or make a purchase according to its own practices and policies. You should carefully review the privacy statement for each product you sign in to and each merchant you purchase from to determine how it will use the data it collects.

Work or business accounts. The data associated with a work or business, and how it will be used, is generally similar to the use and collection of data associated with a personal Apptitude account.

If required by your organization, you will also be asked to provide a phone number or an alternative email address for additional security verification. And, if allowed by your organization, you may also use your work or business account to sign in to Apptitude or third-party products that you acquire for yourself.

If you sign in to Apptitude products with a work or business account, note:

• The owner of the domain associated with your email address may control and administer your account, and access and process your data, including the contents of your communications and files, including data stored in products provided to you by your organization, and products you acquire by yourself.
• Your use of the products is subject to your organization’s policies, if any. You should consider both your organization’s policies and whether you are comfortable enabling your organization to access your data before you choose to use your work or busines account to sign in to products you acquire for yourself.
• If you lose access to your work or business account (if you change employers, for example), you may lose access to products, including content associated with those products, you acquired on your own behalf if you used your work or business account to sign in to such products.
• Apptitude is not responsible for the privacy or security practices of your organization, which may differ from those of Apptitude.
• If your organization is administering your use of Apptitude products, please direct your privacy inquiries, including any requests to exercise your data subject rights, to your administrator. See also the Notice to end users section of this privacy statement.

Third-party accounts. The data associated with a third-party Apptitude account, and how it will be used, is generally similar to the use and collection of data associated with a personal Apptitude account. Your service provider has control over your account, including the ability to access or delete your account. You should carefully review the terms the third party provided you to understand what it can do with your account.

Security of personal data

Apptitude is committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use, or disclosure. For example, we store the personal data you provide on computer systems that have limited access and are in controlled facilities. When we transmit highly confidential data (such as a credit card number or password) over the internet, we protect it through the use of encryption. Apptitude complies with applicable data protection laws, including applicable security breach notification laws.

Where we store and process personal data

Personal data collected by Apptitude may be stored and processed in your region, in the United States, and in any other country where Apptitude or its affiliates, subsidiaries, or service providers operate facilities. Apptitude maintains major data centers in Australia, Austria, Brazil, Canada, Chile, Finland, France, Germany, Hong Kong, India, Ireland, Japan, Korea, Luxembourg, Malaysia, the Netherlands, Singapore, South Africa, the United Kingdom, and the United States. Typically, the primary storage location is in the customer’s region or in the United States, often with a backup to a data center in another region. The storage location(s) are chosen in order to operate efficiently, to improve performance, and to create redundancies in order to protect the data in the event of an outage or other problem. We take steps to ensure that the data we collect under this privacy statement is processed according to the provisions of this statement and the requirements of applicable law wherever the data is located.

We transfer personal data from the European Economic Area and Switzerland to other countries, some of which have not yet been determined by the European Commission to have an adequate level of data protection. For example, their laws may not guarantee you the same rights, or there may not be a privacy supervisory authority there that is capable of addressing your complaints. When we engage in such transfers, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protections travel with your data. To learn more about the European Commission’s decisions on the adequacy of the protection of personal data in the countries where Apptitude processes personal data, see this article on the European Commission website.

Apptitude complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Apptitude has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If third-party agents process personal data on our behalf in a manner inconsistent with the principles of either Privacy Shield framework, we remain liable unless we prove we are not responsible for the event giving rise to the damage. The controlled U.S. subsidiaries of Apptitude , as identified in our self-certification submission, also adhere to the Privacy Shield Principles—for more info, see the list of Apptitude U.S. entities or subsidiaries adhering to the Privacy Shield Principles.

If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, visit the Privacy Shield website.

If you have a question or complaint related to participation by Apptitude in the EU-U.S. or Swiss-U.S. Privacy Shield, we encourage you to contact us via our web form. For any complaints related to the Privacy Shield frameworks that Apptitude cannot resolve directly, we have chosen to cooperate with the relevant Data Protection Authority, or a panel established by the European data protection authorities for resolving disputes. Please contact us if you’d like us to direct you to your data protection authority contacts. As further explained in the Privacy Shield Principles, binding arbitration is available to address residual complaints not resolved by other means. Apptitude is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Our retention of personal data

Apptitude retains personal data for as long as necessary to provide the products and fulfill the transactions you have requested, or for other legitimate purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different data types, the context of our interactions with you or your use of products, actual retention periods can vary significantly.

Other criteria used to determine the retention periods include:

Do customers provide, create, or maintain the data with the expectation we will retain it until they affirmatively remove it? We would aim to maintain the data until you actively delete it, such as by deleting your account (when your account is deleted, its data remain in our system for up to 30 days before final deletion).
Is there an automated control, such as in the Apptitude privacy dashboard, that enables the customer to access and delete the personal data at any time? If there is not, a shortened data retention time will generally be adopted.
Is the personal data of a sensitive type? If so, a shortened retention time would generally be adopted.
Has Apptitude adopted and announced a specific retention period for a certain data type? For example, for Bing search queries, we de-identify stored queries by removing the entirety of the IP address after 6 months, and cookie IDs and other cross-session identifiers after 18 months.
Has the user provided consent for a longer retention period? If so, we will retain data in accordance with your consent.
Is Apptitude subject to a legal, contractual, or similar obligation to retain or delete the data? Examples can include mandatory data retention laws in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or data retained for the purposes of litigation. Conversely, if we are required by law to remove unlawful content, we will do so.

Advertising

Advertising allows us to provide, support, and improve some of our products. Apptitude does not use what you say in email, chat, video calls or voice mail, or your documents, photos, or other personal files to target ads to you. We use other data, detailed below, for advertising in our products and on third-party properties. For example:

Apptitude may use data we collect to select and deliver some of the ads you see on Apptitude web properties, such as Apptitudeglobal.com.
We may share data we collect with third parties, such as Microsoft, Oath, AppNexus, or Facebook (see below), so that the ads you see in our products, their products, or other sites and apps serviced by these partners are more relevant and valuable to you.
Advertisers may choose to place our web beacons on their sites, or use similar technologies, in order to allow Apptitude to collect information on their sites such as activities, purchases, and visits; we use this data on behalf of our advertising customers to provide ads.
The ads that you see may be selected based on data we process about you, such as your interests and favorites, your location, your transactions, how you use our products, your search queries, or the content you view. For example, if you view content on apptitudeglobal.com about automobiles, we may show advertisements about cars; if you search “pizza places in Seattle” on our partner’s search, for example Microsoft’s Bing, you may see advertisements in your search results for restaurants in Seattle.

The ads that you see may also be selected based on other information learned about you over time using demographic data, location data, search queries, interests and favorites, usage data from our products and sites, as well as the sites and apps of our advertisers and partners. We refer to these ads as “interest-based advertising” in this statement. To provide interest-based advertising, we combine cookies placed on your device using information that we collect (such as IP address) when your browser interacts with our websites. If you opt out of receiving interest-based advertising, data associated with these cookies will not be used.

Further details regarding our advertising-related uses of data include:

Advertising industry best practices and commitments. Apptitude adheres to the following self-regulatory programs:
In the US: Digital Advertising Alliance (DAA)
In Europe: European Interactive Digital Advertising Alliance (EDAA)
In Canada: Ad Choices: Digital Advertising Alliance of Canada (DAAC) / Choix de Pub: l’Alliance de la publicité numérique du Canada (DAAC)
Health-related ad targeting. In the United States, we provide interest-based advertising based on a limited number of standard, non-sensitive health-related interest categories, including allergies, arthritis, cholesterol, cold and flu, diabetes, gastrointestinal health, headache / migraine, healthy eating, healthy heart, men’s health, oral health, osteoporosis, skin health, sleep, and vision / eye care. We will also target ads based on custom, non-sensitive health-related interest categories as requested by advertisers.
Children and advertising. We do not deliver interest-based advertising to children whose birthdate in their Apptitude account identifies them as under 16 years of age.
Data retention. For interest-based advertising, we retain data for no more than 13 months, unless we obtain your consent to retain the data longer.
Data sharing. In some cases, we share with advertisers reports about the data we have collected on their sites or ads.
Data collected by other advertising companies. Advertisers sometimes include their own web beacons (or those of their other advertising partners) within their advertisements that we display, enabling them to set and read their own cookie. Additionally, Apptitude partners with third-party ad companies to help provide some of our advertising services, and we also allow other third-party ad companies to display advertisements on our sites. These third parties may place cookies on your computer and collect data about your online activities across websites or online services. These companies currently include, but are not limited to: A9, AppNexus, Criteo, Facebook, MediaMath, nugg.adAG, Oath, Rocket Fuel, and Yahoo!. Select any of the preceding links to find more information on each company’s practices, including the choices it offers. Many of these companies are also members of the NAI or DAA, which each provide a simple way to opt out of ad targeting from participating companies.

Collection of data from children

When a Apptitude product collects age, and there is an age in your jurisdiction under which parental consent or authorization is required to use the product, the product will either block users under that age or will ask them to provide consent or authorization from a parent or guardian before they can use it. We will not knowingly ask children under that age to provide more data than is necessary to provide for the product.

Once parental consent or authorization is granted, the child’s account is treated much like any other account. The child can access our services, and can freely communicate and share data with other users of all ages.

Parents can change or revoke the consent choices previously made, and review, edit, or request the deletion of the personal data of children for whom they provided consent or authorization. For example, parents can revoke access by contacting Apptitude in regards to their child’s account.

Preview or free-of-charge releases

Apptitude offers preview, beta or other free-of-charge products and features (“previews”) to enable you to evaluate them while providing Apptitude with data about your use of the product, including feedback and device and usage data. As a result, previews can automatically collect additional data, provide fewer controls, and otherwise employ different privacy and security measures than those typically present in our products. If you participate in previews, we may contact you about your feedback or your interest in continuing to use the product after general release.

Changes to this privacy statement

We update this privacy statement when necessary to provide greater transparency or in response to:

Feedback from customer, regulators, industry, or other stakeholders.
Changes in our products.
Changes in our data processing activities or policies.
When we post changes to this statement, we will revise the “last updated” date at the top of the statement and describe the changes on the Change history page. If there are material changes to the statement, such as a change to the purposes of processing of personal data that is not consistent with the purpose for which it was originally collected, we will notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification. We encourage you to periodically review this privacy statement to learn how Apptitude is protecting your information.

How to contact us

If you have a privacy concern, complaint, or question for the Apptitude Chief Privacy Officer or Data Protection Officer, please contact us by using our web form. We will respond to questions or concerns within 30 days. You can also raise a concern or lodge a complaint with a data protection authority or other official with jurisdiction.

Our addresses are:

Apptitude, 665 3rd St., Suite 150, San Francisco, CA 94107, USA. Email: support (at) apptitudeglobal.com

To find the Apptitude subsidiary in your country or region, see the list of Apptitude office locations around the world.

Where French law applies, you can also send us specific instructions regarding the use of your personal data after your death, by using our web form.

If you have a technical or support question, please visit Apptitude Support to learn more about Apptitude Support offerings. If you have a personal Apptitude account password question, please visit Apptitude account support.

When you conduct a search, or use a feature of a Bing-powered experience that involves conducting a search or entering a command on your behalf, Microsoft will collect the searches or commands you provide (which may be in the form of text, voice data, or an image), along with your IP address, location, the unique identifiers contained in our cookies or similar technologies, the time and date of your search, and your browser configuration. For example, if you use Bing voice-enabled services, your voice input and performance data associated with the speech functionality will be sent to Microsoft. And, if you use Bing image-enabled services, the image you provide will be sent to Microsoft. When you use Bing-powered experiences, such as Ask Cortana or Bing Lookup to search a particular word or phrase within a webpage or document, that word or phrase is sent to Bing along with some surrounding content in order to provide contextually relevant search results.

Search suggestions. For the search suggestions feature, the characters that you type into a Bing-powered experience to conduct a search will be sent to Microsoft. This allows us to provide you with suggestions as you type your searches. To turn this feature on or off, while using Bing Search, go to Bing Settings. Search Suggestions cannot be turned off in Cortana. On Windows, you can always hide Cortana and the search box so as not to use the feature.

Bing experience improvement program for Bing Desktop and Bing Toolbar. If you are using Bing Desktop or Bing Toolbar and choose to participate in the Bing Experience Improvement Program, we also collect additional data about how you use these specific Bing apps, such as the addresses of the websites you visit, to help improve search ranking and relevance. To help protect your privacy, we do not use the data collected through the Bing Experience Improvement Program to identify or contact you or target advertising to you. You can turn off the Bing Experience Improvement Program at any time in the Bing Desktop or Bing Toolbar settings. Finally, we delete the information collected through the Bing Experience Improvement Program after 18 months.

Retention and de-identification. We de-identify stored search queries by removing the entirety of the IP address after 6 months, and cookie IDs and other cross-session identifiers after 18 months.

Personalization through Microsoft account. Some Bing services provide you with an enhanced experience when you sign in with your personal Microsoft account, for example, syncing your search history across devices. You can use these personalization features to customize your interests, favorites, and settings, and to connect your account with third-party services. Visit Bing Settings to manage your personalization settings, or the Microsoft privacy dashboard to manage your data.

Managing search history. When you’re signed-in to a personal Microsoft account, you can erase your search history on the Microsoft privacy dashboard. The Search History service from Bing, located in Bing Settings, provides another method of revisiting the search terms you’ve entered and results you’ve clicked when using Bing search through your browser. You may clear your search history on a device through this service. Clearing your history prevents that history from being displayed on the Search History site, but does not delete information from our search logs, which are retained and de-identified as described above or as you have instructed through the privacy dashboard.

Third-party services that use Bing. You may access Bing-powered experiences when using third-party services, such as those from Yahoo!. In order to provide these services, Bing receives data from these and other partners, including your search query and related data (such as date, time, IP address, and a unique identifier). This data will be sent to Microsoft to provide the search service. Microsoft will use this data as described in this statement or as further limited by our contractual obligations with our partners. You should refer to the privacy policies of the third-party services for any questions about how they collect and use data.

Search query passed in referral URL. When you select a search result or advertisement from a Bing search results page and go to the destination website, the destination website will receive the standard data your browser sends to every web site you visit—such as your IP address, browser type and language, and the URL of the site you came from (in this case, the Bing search results page). Because the URL of the Bing search results page contains the text of the search query you entered (which could include names, addresses, or other identifying information), the destination website will be able to determine the search term you entered.

If your browser is enabled to allow pages to pre-load in the background for faster performance, when your browser loads a page in the background, it will have the same effect as if you visited that page, including sending the Bing search results page URL (containing your search query) and downloading any cookies or similar technologies that page sets.

Sharing data from Bing and Bing-powered experiences with third parties. We share some de-identified data (data where the identity of a specific person is not known) from Bing and Bing-powered experiences with selected third parties. Before we do so, we run the data through a process designed to remove certain sensitive data that users may have included in the search terms themselves (such as social security numbers or credit card numbers). Additionally, we require these third parties to keep the data secure and to not use the data for purposes other than for which it is provided.