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MOBILE APP | PRIVACY STATEMENT

Last updated: 30 May 2023


This privacy policy applies to Affinity Global Inc. its performance marketing platform VEVE (collectively, “VEVE,” or “we“, “us“, “our“) and covers mobile applications which Affinity Group offers.

This Privacy Policy describes how VEVE collects, uses, and discloses information, and what choices you have with respect to the information.

Services

VEVE offers a performance marketing platform to reach consumers through OEMs and browsers. We help driving new customer acquisitions, sales, app downloads and website views through unique formats and media placements.

VEVE engages with third party publishers to serve ads on their digital properties on behalf of its demand side advertising partners. VEVE also engages in media planning and measurement (e.g. whether an advertisement was viewed, its timestamp etc.)

VEVE provides performance marketing platform Services, including optimization of advertising campaigns, data analytics/enrichment, segment creation, user acquisition or re-engagement through various digital advertising channels. VEVE receives data into its marketing platform from various sources, including end user information collected by our systems, applications, business partners or customers, which may include third party apps and services that you use. Please refer to the privacy policies of the OEMs, apps and services you use to understand how those apps and services collect, use and share data from your interactions with them. VEVE is not responsible for how those third-party services collect and use data.

We also provide mobile app to our publishers and advertisers which gives them access to their account information, statistics & reporting, performance dashboard.

Some of the apps also provide marketplace for publishers and advertiser where they can engage to initiate a deal.

We are committed to protecting your privacy. The purpose of this notice is to supply you with the required information at the time of providing us with your personal data. This Privacy Notice explains how we collect, use and disclose your personal data and what rights and options you have in this respect. This should help you feel more confident about privacy and security of your personal data.

It is our policy to respect your privacy regarding any information we may collect while using our services and websites, collectively called the Services.

It is our policy to respect your privacy regarding any information we may collect while using our services and websites, collectively called the Services.

Information We Collect

When you download and register on our app, we collect following information about you:

  • Device identifiers such as iOS devices’ Identifier for Advertising (IDFA), or Android ID for Android devices
  • Other information such as Device Type, Operating System and Language settings
  • Details you provide before downloading our app
    • Name of your organization
    • Your name
    • Business email
    • Contact number

We also collect information when you use our app:

  • Our servers automatically collect information when you access or use our applications and services. This data is recorded in log files. Examples of such data include IP Address.
  • Subscription Data – You provide personal data to us as part of signing up for communication from us through our apps. We may also collect personal information from you when you use interactive features of the Websites, promotions, requesting customer support, or otherwise communicating with us.
    • We also use Amplitude Analytics to  track your actions and better understand what’s working and what’s not.

How We Use Your Data

We use your data for following purposes:

  • To analyse and provide you reports / dashboards on the effectiveness of advertisements and campaigns, including across different types of devices based on our determination of devices that are related to the same person.
  • To provide you access to all traffic performance data and key metrics
  • To provide business related notifications
  • To provide periodic communication about new publishers & advertisers as well as billing and other account specific information
  • To provide you effective customer service
  • Internal business reporting

Lawful bases for processing

We process your personal data only when we have a lawful basis. Presently, we use the Performance of Contract (i.e. to deliver the services to our customers) and consent as the lawful basis for processing. For certain processing, we may also use legitimate interests as provided under the Data Protection Regulations.

In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

Where you have consented to a particular processing, you have a right to withdraw the consent at any time.

Children under 16 years of age

We do not knowingly collect personal information from children under the age of 16

If you are under the age of 16, you are not permitted to use the Services or to disclose Personal Information. If we learn we have collected or received Personal Information from a child under 16, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us.

Holding Personal Data:

We hold Personal Data in electronic formats. In some cases, we engage third parties to host electronic data (including data about the services we provide) on our behalf. We take security measures to protect the Personal Data we hold which includes physical controls (for example, security passes to enter our offices and storage of files in lockable cabinets) as well as technological controls (for example, restriction of access, firewalls, the use of encryption, passwords and digital certificates).

We also have policies and processes which govern document retention and data breach incidents. We endeavour to ensure that Personal Data is kept as current as possible and that irrelevant or excessive data is deleted or made anonymous as soon as reasonably practicable. However, some Personal Data may be retained for varying periods to comply with legal and regulatory obligations and for other legitimate business reasons.

Data Retention Policy

We will retain your information for up-to 3 years after our contract with you expires. After the applicable retention period, we may only retain and use your data:

  1. in an aggregated or anonymized format;
  2. to comply with its legal obligations;
  3. to resolve disputes and enforce agreements.

Please note that the use cases stated in this provision will apply as an exception to your data subject or consumer rights related requests.

Your Rights

Data Subjects have certain rights in respect of their personal data. The rights given with respect to your personal data include:

  • The Right of Access: You have the right to access personal data and supplementary information. You can ask us for a copy of your personal information.
  • The Right to Rectification: You can ask us to change, update or fix your data in certain cases, particularly if it is inaccurate.
  • The Right to Erasure: You can ask us to erase or delete all or some of your personal information (e.g., if it is no longer necessary to provide Services to you) without undue delay.
  • The Right to Restriction of Processing: You can ask us to stop using all or some of your personal information (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if you think your personal information is inaccurate or unlawfully held).
  • The Right to Data Portability: You have the right to data portability which provides the right to receive your personal data in a structured, commonly used and machine-readable format, and have the right to transmit the same to another controller.
  • The Right to Object: You have the right to object to the processing of personal data.
  • Automated individual decision-making, including profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you (data subject).
  • The right to withdraw consent: You have the right to withdraw your consent at any time with effect for the future. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
  • The right to lodge a complaint: You have the right to lodge a complaint with the supervisory authority if you are dissatisfied with the way we handle or process your personal data.

Whenever you use our services, we aim to provide you with easy means to access, modify, delete, object to or restrict the use of your personal information.

We strive to give you ways to access, update/modify your data quickly, or delete it unless we have to keep that information for legal purposes. These rights can be exercised by contacting us using the details set out in the "Contact Information" section below.

Account Closure

We keep some personal data even after account closure

Once you choose to close your account, we generally delete your personal information within 3 years of closure of your account. Some information that is necessary for statutory obligations such as records of payment processing, invoicing data will be retained as necessary.

Your information shared with others

Recipients of your data

VEVE may share the Website user’s data we collect or receive about you as described in this Policy as follows:

  • Employees and Subsidiaries - We at VEVE might share your personal data with our employees, subsidiaries that need to know in order to help us provide our services or to process the information on our behalf.
  • Service Providers - We may share personal information we collect about you with our third- party service providers. The categories of service providers to whom we entrust personal information include: IT and related services such as cloud-based data centers, analytics service providers; service providers for fraud detection; CRM and email marketing services.
  • Disclosures to Protect Us or Other - We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
  • Disclosures in the Event of Merger, Sale, or Other Asset Transfers - If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
  • Legal Requirement - We provide your personal data when we are required to provide such information in response to a court order or other applicable law or legal process
  • Regulators and Auditors - VEVE may share the personal data with the regulators, the Financial Conduct Authority, or any relevant regulatory authority where they are entitled to the disclosure. Also, we may be required to share information with auditors appointed by the providers of such products or services.

We may also share your information in following circumstances:

  • To prevent, investigate, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Service or any other agreement related to the services, or as otherwise required by law.
  • To help us conduct marketing and/or advertising campaigns
  • To conform to legal requirements, or to respond to lawful court orders, subpoenas, warrants, or other requests by public authorities (including to meet national security or law enforcement requirements).
  • Personal information may also be shared with a company that acquires our business, whether through merger, acquisition, bankruptcy, dissolution, reorganization, or other similar transaction or proceeding. If this happens, we will post a notice on our home page.
  • VEVE will always ask for your consent before sharing your personal information with third parties for uses other than those mentioned in this section.

Cross-Border Data Transfers

Your data will be stored and processed in multiple countries including outside of the European Union (EU) Region

Since we are an international company, your data will be processed outside of the EU region. Your data will be processed within Third Party Data Centers in Europe and India as well as VEVE data center in USA. Some countries where we process data may not have as protective laws as your own country and there are risks associated with such transfer.

VEVE offers European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our publishers and advertisers that operate in the European Union, and other international transfers of data. These clauses are contractual commitments between parties transferring personal data (for example, between VEVE and its Clients, suppliers or data processors outside the EU), binding them to protect the privacy and security of the data.

Security Measures to Protect your Data

Security Measures

We implement security controls to prevent breaches and unauthorised access to your data.

We maintain reasonable and appropriate security measures to protect Customer Data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.

Examples of security measures include physical access controls, restricted access to data, monitoring for threats and vulnerabilities etc.

Protection of personal information

Our Sites and Services uses commercial efforts to maintain safeguards for protection of your Personal Information

VEVE takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personally-identifying and personally-identifying information.

Other Information

Contact Information

You can contact us about this privacy policy or use of our services.

If you have questions or complaints regarding this Policy, you may contact us through email at compliance@affinity.com. You may contact us at our mailing address below

20 N. Wacker Drive, 12th Floor,
Chicago, IL 60606

If you are a resident of the European Economic Area and we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you have additional rights. If you are not satisfied with the resolution, you can also lodge a complaint with the Supervisory Authority in the country of your residence.

Privacy policy change

VEVE may change this Privacy Policy from time to time, at our sole discretion.

VEVE encourages visitors and customers to frequently check this page for any changes to its Privacy Policy. We will notify you of material changes in advance by email or by notice when you log in to the Sites and Services or both. You confirm that your continued use of our services after any change in this Privacy Policy will constitute your acceptance of such changes and agree to be subject to the revised privacy policy.

ANNEXURE:

Jurisdiction-specific provision:

California Privacy Rights Act(CPRA)

This CPRA Privacy Policy describes VEVE practices regarding the collection, use, and disclosure of the personal information of California residents, describes the rights of California residents under the California Privacy Rights Act (“CPRA”), and explains how California residents may contact VEVE to exercise those rights. This CPRA Privacy Policy only applies to the personal information of California residents.

CPRA Categories of Personal Data

Categories of Personal data Personal data collected
Identifiers

Name, postal address, phone number, email address etc.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Name, signature, tax identification number (i.e. National Insurance Number), Government ID number etc. for individual who are signing up as our partners and customers.
Financial Information Bank details, payment information etc.
Commercial Information If any collected
Protected Classification characteristics under California or federal law. N/A - We do not collect information such as Gender, Age, national origin, marital status etc.
Biometric information N/A - We do not collect Biometric information
Internet or other similar network activity. Log data, session information, Cookie Id .
Geolocation data

Such as your location information generated based on your IP address etc. when consented by the individual.

  • Location information such as country code we infer from your device’s IP address
  • We do not collect the precise location of the Website visitors
Sensory data. N/A - We do not collect any Sensory data.
Professional or employment-related information. N/A
Inferences drawn from other personal information. If any collected
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). N/A

No Sale of Personal Data:

VEVE has not sold Personal Data in the preceding twelve (12) months.

Right To Opt-Out Of The Sale Of Personal Data:

VEVE does not sell your personal data.

If in case, VEVE ever changes its policy and choose to sell Personal Data, you would have the right to opt-out of the sale of your Personal Data by clicking on the Do Not Sell My Personal Info link.

Sensitive data:

We do not generally seek to collect sensitive data through this site or otherwise. In the limited cases where we do seek to collect such data, we will do this in accordance with California Privacy Rights Act ("CPRA") requirements. If in case, VEVE ever chooses to use Sensitive Personal Data, you would have the right to limit the use of your sensitive personal Data

The term "sensitive data" refers to the various categories of personal data identified by CPRA as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical, or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic data, sexual life or orientation, or criminal convictions and offences (including information about suspected criminal activities).

Disclosures of Personal Data for a Business Purpose:

In the preceding twelve (12) months, VEVE has not disclosed Personal Data for business purposes.

Your Rights:

The CPRA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CPRA rights and explains how to exercise those rights.

  • Access to Specific Information

    You have the right to request that Affinity disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

    • The categories of personal information we collected about you.
    • The categories of sources for the personal information we collected about you.
    • Our business or commercial purpose for collecting or selling that personal information.
    • The categories of third parties with whom we share that personal information.
    • The specific pieces of personal information we collected about you (also called a data portability request).
    • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
      • Sales, identifying the personal information categories that each category of recipient purchased; and
      • Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
  • Deletion Request Rights

    You have the right to request Affinity delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

    • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    • Exercise free speech, ensure the right of another consumer to exercise their free speech rights or exercise another right provided for by law.
    • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
    • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement if you previously provided informed consent.
    • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
    • Comply with a legal obligation.
    • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
  • Right to Correct Inaccurate Personal Information

    You have a right to request for correction of Inaccurate personal information. We shall use commercially reasonable efforts to correct the inaccurate personal information as directed by the consumer.

  • Right to Know What Personal Information is Sold or Shared and to Whom

    You have a right to request us information about what personal information is sold or shared by us and with whom. Once request received, we shall disclose the following:

    • The category or categories of consumers’ personal information it has sold or shared, or if we have not sold or shared consumers’ personal information, it shall disclose that fact.
    • The category or categories of consumers’ personal information it has disclosed for a business purpose, or if we have not disclosed consumers’ personal information for a business purpose, it shall disclose that fact.
  • Right to Opt Out of Sale or Sharing of Personal Information

    You have a right to opt out of sale or sharing of personal information if we sell or share such personal information. We shall prohibit from selling or sharing the consumer’s personal information after its receipt of the consumer’s direction, unless the consumer subsequently provides consent, for the sale or sharing of the consumer’s personal information.

  • Right to Limit Use and Disclosure of Sensitive Personal Information

    You have a right to request us to limit Use and Disclosure of Sensitive Personal Information. Upon such request we shall prohibit, from using or disclosing the consumer’s sensitive personal information for any other purpose after its receipt of the consumer’s direction unless the consumer subsequently provides consent for the use or disclosure of the consumer’s sensitive personal information for additional purposes.

  • Right of No Retaliation Following Opt Out or Exercise of Other Rights – Non-Discrimination

    We will not discriminate against you for exercising any of your CPRA rights. Unless permitted by the CPRA, we will not:

    • Deny you goods or services.
    • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
    • Provide you a different level or quality of goods or services.
    • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

    Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

    You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

    • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
    • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

    We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

  • Response Timing and Format

    We endeavour to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

    Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

    We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

CONTACT FOR MORE INFORMATION

If you have any questions or concerns about VEVE’s privacy policy and practices, please contact us by email at compliance@affinity.com , or by mail at:

20 N. Wacker Drive, 12th Floor,
Chicago, IL 60606

Privacy policy change

We will review and update this CPRA Privacy Policy periodically and will note the date of its most recent revision at the top of this CPRA Privacy Policy. If we make material changes to this Policy, we will post the revised Policy on our website and may take additional measures to inform you about such changes prior to such changes taking effect, if required by applicable data protection laws. We encourage you to review this Policy frequently to be informed of how VEVE is protecting your information.

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