I. Introduction
Apptronic, a property of 12 Baskets Limited Liability Corporation (“Apptronic,” “we,” “us,” or “our”), provides digital advertising technology platforms (“Technology”) to facilitate contextual (non-personalized) and targeted (personalized) advertising (“Services”). We work with advertisers and their partners (“Buyers”) on websites and properties (“Seller Sites”) owned by participating entities (“Sellers”). This Privacy Policy outlines our data collection and usage practices for end-users and partners.
II. Scope of this Privacy Policy
This policy applies when:
- We collect information from consumers interacting with our Services and Technology on Seller Sites.
- Buyers, Sellers, potential Buyers, potential Sellers, or other end-users interact with our website (www.apptronic.co) (“Website”).
III. Notice at Collection
This section details the information we collect and its purposes, covering both our Website and our Services.
A. End-User Data Collection
Our Technology collects information from end-users visiting Seller Sites and/or our Website. While this data doesn’t directly identify you (e.g., name, email), it may be considered “personal data” under applicable laws.
1. Information Collected:
- Online Identifiers: IP address, device IDs, cookie identifiers, advertising identifiers (IDFA and Google AdID), other mobile identifiers.
- Seller Site Information: Web page URL, referrers, viewability data, contextual categories, ad format attributes, click data, viewed ad types, other data provided by Seller Sites.
- Device Information: Browser, device model, device operating system, browser language, device type.
- Location Information: Non-precise location (city, country, zip code), precise location (with opt-in).
- Website Usage Data: Web page interactions, time spent on pages, referral web pages.
- Non-Cookie Identifiers: Local storage or browser cache.
- Third-Party Information: Demographics, behaviors, interests, hashed email addresses, ad preferences, other data for ad relevance.
2. Cookies and Other Tools: We use cookies, web beacons, mobile SDKs, and other tools (“Tools”) for:
- Frequency Capping: Limiting ad repetition.
- Research and Fraud Prevention: Identifying fraud and malicious activity.
- Our Services: Delivering targeted (behavioral/interest-based) and contextual advertising.
We do not collect sensitive personal information or target ads based on medical conditions. However, we may serve non-sensitive health-related ads based on content or user interests.
B. End-User Data Usage
We use end-user data for:
- Fraud Monitoring: Detecting click-fraud and other advertising fraud.
- Ad Selection and Delivery: Presenting contextually relevant or interest-based ads.
- Service Improvement: Combining user data with partner and third-party data for analytics and insights.
- Frequency Capping: Limiting ad repetition.
- Data Privacy Compliance: Responding to privacy requests.
C. End-User Data Sharing
We may share end-user data with:
- Service Providers (“Vendors”): For operational services (attribution, analytics, billing, fraud prevention, etc.). Vendors are contractually prohibited from using data except to provide services to us.
- Buyers: For ad buying decisions, campaign analysis, business opportunity exploration, audits, and research.
- Sellers: To enable Sellers to infer user preferences for relevant advertising.
- Legal and Government Authorities: For legal processes, protecting our rights, security, and integrity, or as required by law.
- Acquisitions and Corporate Partners: In connection with substantial corporate transactions.
We may also share aggregated, non-identifiable data with third parties. We will only share your information with anyone if we have your express consent.
IV. Partner Data Collection and Usage
A. Partner Data Collection
We collect information from partners when they contact us, register for our services, or use our Website/interfaces.
1. Information Collected:
- Contact Information: Name, email, mailing address.
- Government Identifiers: Driver’s license number, other identifiers.
- Financial Information: Bank account, payment information.
- Online Identifiers: IP address, device IDs, cookie identifiers, location information.
- Device Information: Browser, device type.
- Usage Data: Browsing/search history, web page interactions, referral web page, Website usage.
- Cookies: We use cookies, web beacons, and other tools for website functionality, usage analysis, and improvement.
B. Partner Data Usage
We use partner data for:
- Customer Service: Responding to inquiries, troubleshooting, providing support.
- Marketing: Analyzing signups, supporting sales, delivering targeted advertising.
- Service Provision: Combining data for service delivery, analysis, and improvement.
- Compliance/Security: Verifying signups, ensuring traffic quality, protecting data
- Data Privacy Compliance: Responding to privacy requests.
- Legal Obligations: Complying with legal requirements.
C. Partner Data Sharing
We may share partner data with:
- Vendors: For operational services, subject to contractual data protection obligations.
- Legal and Government Authorities: For legal processes, protecting our rights, security, and integrity, or as required by law.
- Acquisitions and Corporate Partners: In connection with substantial corporate transactions.
We may also share aggregated, non-identifiable data with third parties
V. Your Choices
You can manage cookies through your browser settings (delete, disable). Mobile devices offer options to turn off or reset ad identifiers (“Opt out of Personalized Ads” on Android, “Limit Ad Tracking” on iOS).
You can opt out of interest-based advertising via our opt-out tool (https://www.Apptronic/optout/), the NAI opt-out tool ([invalid URL removed]), or www.aboutads.info/choices (US) and www.youronlinechoices.com (EU/UK).
Some partners have their own opt-out mechanisms. See their privacy policies. Google’s privacy policy is available here.
VI. Rights for Washington Consumers
This section describes the rights of Washington consumers under the Washington Consumer Privacy Act (CCPA).
A. Collection of Personal Information
- Categories Collected: Unique device identifiers (cookies, mobile ad IDs), timestamps, user agent strings, IP addresses, general location data, precise location information, internet activity information, browsing history. We collect identifiers, professional information, internet activity, and geolocation from partners.
- Usage: Delivering and measuring online advertising. We use partner data for marketing and service provision.
- Sources: Websites, mobile applications, advertising services, technology platforms. We collect data directly from partners and their use of our platforms.
B. Disclosure of Personal Information
We share information as described earlier. We “sell” identifiers and inferences about website visitors.
- Purposes of Sale: Tailored advertising, marketing, measurement, analytics, and research.
- Categories of Third Parties Sold To: Advertisers, agencies, marketers, technology platforms, websites, market research firms.
- Categories of Third Parties Disclosed To (Sold or Shared) for Business Purposes: Same as above.
C. Washington Consumer Rights & Options
You have the right to access, correct, or delete your personal information. You can limit the use of sensitive personal information (if we ever collect it). Exercise your rights via a privacy request here or by emailing privacy@apptronic.co. Opt-out of sale/sharing via our opt-out tool or by sending a GPC signal. We may set a non-unique cookie to implement your opt-out. Opt-out choices should be repeated if cookies are deleted. We may not be able to provide copies of personal information if we cannot verify your identity. We will treat deletion requests for unidentifiable information as opt-out requests. We honor opt-out requests from recognized global privacy controls. Authorized agents must provide proof of authority. Contact our privacy officer with questions. We will not discriminate against you for exercising these rights.
D. Washington Consumer Rights Request Metrics (2023)
- Deletion Requests: Received: 1; Fulfilled: 1; Denied: 0; Median fulfillment time: 10 days.
- Opt-Out Requests: Received: 221; Fulfilled: 221; Denied: 0; Median fulfillment time: 1 day.
- Right to Know Requests: Received: 0; Fulfilled: 0; Denied: 0; Median fulfillment time: N/A.
- Limit Use Requests: N/A (we don’t collect sensitive information).
E. Rights of Consumers in Other U.S. States
Consumers in Virginia, Connecticut, Colorado, Oregon, Texas, Utah, Montana, Delaware, Iowa, Nebraska, New Hampshire, and New Jersey have the right to:
- Confirm whether or not we are processing your personal information and access your personal information.
- Correct inaccuracies in your personal data and the purposes for which we are processing it.
- Delete your personal information.
- Obtain a copy of personal data you have previously provided to us, or in some states, all the personal data we have obtained about you, in a form that allows it to be shared with another controller.
- Opt out of targeted advertising.
- Opt out of the sale of your personal information.
- Opt out of profiling that would be used for significant decisions about you.
If and when global privacy controls or other universal opt-out mechanisms are approved and honoring them is required in your state, you will also have the right to opt-out of sale, targeting, or profiling, or all of these, using these browser-based controls.
We will not discriminate against you in any way for exercising these rights.
For certain requests, we may email you to confirm your identity. You can email us at privacy@apptronic.co or make your request here.
F. Legal Basis for our Processing of Your Personal Information
We rely on the following lawful bases to process your Personal Information:
- Consent: We rely on your freely given, specific, informed agreement for placing Tools on your browser/device and using them to store information, providing personalized advertising, and delivering personalized content. For Website analytics, we rely on consent or legitimate interest, depending on the data and the legal basis used by Sellers and Buyers.
- Legitimate Interest: We process data for our business interests in conducting and managing our operations, providing the best service/product, and ensuring a secure experience. We balance our interests against your potential impact and rights. We may use limited information (e.g., content viewed, general location) for basic ads, believing the minimal risk is outweighed by the benefits of supporting content delivery. We also rely on legitimate interest for frequency capping, fraud detection, measuring ad performance, and supporting, developing, and improving our Services. You can obtain further information about our legitimate interest assessments by submitting a privacy request or contacting us at privacy@apptronic.co.
- Performance of Contract: We process data necessary for performing a contract with you or taking steps at your request before entering a contract. This applies to processing business contact information of Partners and clients.
- Comply with a Legal or Regulatory Obligation: We process data to comply with legal obligations, such as responding to requests from law enforcement or other authorities.
G. Participation in the Advertising Industry Transparency and Consent Framework
We participate in the IAB Europe’s Transparency and Consent Framework (“TCF”), which provides transparency and control over who processes your personal information.
H. Sharing of Personal Information
We share information as described earlier in this policy.
I. Additional EU/UK Privacy Rights
If we rely on your consent, you can withdraw it anytime. You can request correction or erasure of your data, object to processing or automated decision-making. Exercise these rights via a privacy request or by contacting privacy@apptronic.co.
J. Modifications to this Privacy Policy
We may update this policy. Material changes will be announced on our Website or through a notice. Continued use after the effective date signifies agreement to the updated policy.
K. Cross-Border Transfers
Our infrastructure is primarily in the United States. By using our Website, you agree to transfer your data to the U.S. and other countries. For EU/UK users, we ensure appropriate safeguards, such as Standard Contractual Clauses, for data transfers outside the EU/UK.
VII. Sensitive Information
Do not send us sensitive personal information (e.g., social security numbers, racial/ethnic origin, political opinions, religion, health, criminal background, trade union membership).
VIII. Third-Party Practices
This policy applies only to our practices. Review the privacy policies of other websites you visit.
IX. Data Retention
We retain information as long as necessary for the purposes collected, including legal requirements. We consider the data’s nature, sensitivity, potential harm, processing purposes, and legal requirements. Unless legally required, we retain non-aggregated data for up to 24 months, after which it is anonymized or deleted. Aggregated data may be retained longer. EU/UK users can request data deletion. We use reasonable security measures but cannot guarantee data security during transmission.
X. Children
Our Website is for users above 18. We do not knowingly collect data from children under 16 (or other locally restricted age). Contact us if you believe your child has provided information.
XI. Contact Us
For privacy policy questions, contact us at privacy@apptronic.co or mail us at:
Privacy Officer
Apptronic (12 Baskets Limited Liability, Corp)
11511 NE 195th ST
Bothell, WA 98011