We at Apkudo (Apkudo, Inc. and the Apkudo affiliates listed in Annex 3 to the Data Processing Agreement) are committed to protecting your privacy. This Privacy Policy applies to the information and data collected by Apkudo as a controller, including the information collected on our Websites (www.apkudo.com, www.channelm.io, and www.trovetrade.app) or through other channels as described below. This Privacy Notice describes how we collect, receive, use, store, share, transfer, and process your personal information. It also describes your choices regarding use, as well as your rights of access and correction of your personal information. If you do not agree with the data practices described in this Privacy Policy, you should not use the Websites.
This Privacy Policy does not apply to the data Apkudo processes on behalf of our customers (Customer Data) in our capacity as a processor. Your use of the Apkudo Subscription Service (the Subscription Service) as a customer of Apkudo, including use of our associated mobile applications (Mobile Apps), is covered under the Apkudo Product Privacy Policy.
We periodically update this Privacy Policy. We will post any privacy policy changes on this page and, if the changes are material, we will provide a more prominent notice by sending you an email notification, or if you subscribe to the Subscription Service, through the Notification app in your Apkudo portal.
While we will notify you of any material changes to this Privacy Policy prior to the changes becoming effective, we encourage you to review this Privacy Policy periodically. We will also keep prior versions of this Privacy Policy in an archive for your review.
If you have any questions about this Privacy Policy or our treatment of the information you provide us, please use email us at privacy@apkudo.com or write to us by mail to Apkudo, Inc., 3500 BOSTON STREET SUITE #330, MS-48 BALTIMORE MD 21224 USA, Attn: Privacy.
Our Use of the Subscription Service
Information that we collect and manage using the Subscription Service for our own marketing belongs to us and is used, disclosed and protected according to this Privacy Policy.
When You Visit our Websites
You are free to explore the Websites without providing any Personal Information about yourself. When you visit the Websites or register for the Subscription Service, we request that you provide Personal Information about yourself, and we collect Navigational Information.
"Personal Information"
We collect personal information from you when you submit web forms or interact with our Website, for example submitting a Contact Us webform or requesting customer support. We also collect personal information when you sign up for a Apkudo account.
"Personal Information" refers to any information that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business. Personal Information can also include information about any transactions, both free and paid, that you enter into on the Websites, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, or information that we acquire from service providers.
Personal Information includes Navigational Information or Payment Information where such information can directly or indirectly identify an individual.
"Sensitive Information"
This refers to credit or debit card numbers, financial account numbers or wire instructions, government issued identification numbers (such as Social Security numbers, passport numbers), biometric information, personal health information (or other information protected under any applicable health data protection laws), personal information of children protected under any child data protection laws, and any other information or combinations of information that falls within the definition of “special categories of data” under GDPR or any other applicable law relating to privacy and data protection.
Log Files
When you view content provided by us, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. This information is used by Apkudo to provide general statistics regarding use of the Websites. For these purposes, we do link this automatically-collected data to other Personal Information such as name, email address, address, and phone number.
Information we collect from third parties
From time to time, we may receive Personal Information about you from third party sources including partners with which we offer co-branded services or engage in joint marketing activities, and sources such as social media websites.
The Websites are not intended for or targeted at children under 16, and we do not knowingly or intentionally collect personal information about children under 16 If you believe that we have collected personal information about a child under 16, please email us at privacy@apkudo.com , so that we may delete the information.
Compliance with Our Privacy Policy
We use the information we collect only in compliance with this Privacy Policy. Customers who subscribe to our Subscription Services are obligated through our agreements with them to comply with this Privacy Policy.
We Never Sell Personal Information
We will never sell your Personal Information to any third party.
Use of Personal Information
In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Information to:
We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your Personal Information to the third party.
Legal basis for processing Personal Information (EEA visitors only)
If you have questions and are a visitor located in the European Economic Area ("EEA"), you can email Apkudo's Data Protection Officer at privacy@apkudo.com .
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
Use of Navigational Information
We use Navigational Information to operate and improve the Websites and to provide you with a better experience when you interact with Apkudo. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalized information about Apkudo. Navigational Information, such as IP address, is used to approximate your location. For example, we may use your approximate location to provide content that has been translated or send emails at certain times using your local time zone.
You may disable the collection and use of your location data through browser-, operating system- or device-level settings.
Customer Testimonials and Comments
We post customer testimonials and comments on our Websites, which may contain Personal Information. We obtain each customer's consent via email prior to posting the customer's name and testimonial.
Use of Payment Information
If you give us Payment information, we use it solely as authorized by you in accordance with this Privacy Policy in order for you to use the Subscription Services, including to check your financial qualifications and collect payment from you. We use a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use information you provide except for the sole purpose of credit card processing on our behalf.
Security of your Personal Information
We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Information is protected using appropriate physical, technical and organizational measures. For more on Security at Apkudo, please see https://apkudo.trustcenter.sprinto.com
Social Media Features
Our Websites include Social Media Features, such as the Facebook Like button and Widgets, such as the Share Button or interactive mini-programs that run on our sites. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Websites. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.
External Websites
Our Websites provide links to other websites of third parties. We do not control, and are not responsible for, the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to any privacy and other policies they may have.
Retention of Personal Information
How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.
We retain Personal Information that you provide to us where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes and enforce our agreements)
When we have no ongoing legitimate business need to process your Personal Information, we securely delete the information or anonymize it or, if this is not possible, securely store your Personal Information and isolate it from any further processing until deletion is possible. We will delete this information at an earlier date if you so request, as described in the "How to Access & Control Your Personal Data" below.
If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your Apkudo account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
The data our customers collect by using the Subscription Service is retained according to the relevant agreements with our customers.
Service Providers
We employ other third-party service providers to provide services on our behalf to visitors to our Websites and our customers and users of the Subscription Service and may need to share your information with them to provide information, products or services to you. We might also share data with third parties but only if the data has been de-identified in a way so it cannot be used to identify you. Examples may include removing repetitive information from prospect lists, analyzing data or performing statistical analysis on your use of the Subscription Service or interactions on our Websites, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, developing and improving the product and services, and providing customer service or support. These service providers are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and data protection policies and standards.
Apkudo Partners
In addition, we may share data with trusted partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide customer support. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information.
We partner with trusted third parties to provide you with co-marketing content that we think may be relevant to you. When you engage with these co-marketing partners, we will tell you who we are sharing data with and provide a link to the co-marketing partner’s privacy policy so you can learn more about how to opt-out of the partner’s communications. These co-marketing partners are required to adhere to our privacy and data protection policies. If you do not want us to share your personal information with these companies, please contact us at privacy@apkudo.com .
Corporate Events
If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by Apkudo on the Websites and the Subscription Service. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.
Compelled Disclosure
We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.
To facilitate our global operations, we transfer information and allow access to that information from countries in which the Apkudo affiliated entities have operations for the purposes described in this policy.
This Privacy Policy shall apply even if we transfer Personal Information to other countries. We have taken appropriate safeguards to require that your Personal Information will remain protected. Please see our Privacy Framework notice below for more information.
International transfers to third parties
Some of the third parties described in this privacy policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we share information of customers in the EEA or Switzerland, we make use of a variety of legal mechanisms to safeguard the transfer, including the European Commission-approved standard contractual data protection clauses, or other appropriate legal mechanisms. For transfers to or from the United Kingdom, we make use of the standard contractual clauses. Please contact us if you need more information about the legal mechanisms we rely on to transfer Personal Information outside the EEA, Switzerland and the United Kingdom.
Privacy Framework Notice
Apkudo adheres to the U.S. Department of Commerce’s Privacy Framework available at https://www.dataprivacyframework.gov/.
Apkudo is responsible for the processing of personal data it receives under Privacy Frameworks and subsequently transfers to a third party acting as an agent on its behalf. Apkudo complies with the Privacy Framework Principles for all onward transfers of personal data from the EEA, the United Kingdom, and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Framework, Apkudo is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Apkudo may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
You may direct any inquiries or complaints related to our Privacy Framework by emailing us at privacy@apkudo.com .
Under certain conditions, more fully described on the Privacy Framework website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
Apkudo and our partners use cookies or similar technologies (such as web beacons and JavaScript) to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. To find out more about how we use cookies on our Websites and how to manage your cookie preferences please see our Cookie Policy.
Navigational Information Collected by Our Customers
Our customers can use the tools we provide, as well as tools provided by third parties, to collect Navigational Information when you visit their webpages on the Subscription Service. Apkudo does not control our customers' use of these tools, nor do we control the information they collect or how they use it.
Advertising
We partner with a third party ad network to either display advertising on our Web site or to manage our advertising on other sites. Our ad network partner uses cookies and Web beacons to collect information about your activities on this and other websites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here: http://optout.aboutads.info/ or http://optout.networkadvertising.org/ (or if located in the European Union, by clicking here: http://www.youronlinechoices.eu/). Please note this does not opt you out of being served advertising. You will continue to receive generic ads.
Third Party Tracking Technologies
The use of cookies and web beacons by any tracking utility company is not covered by our Privacy Policy or Cookie Policy.
Reviewing, Correcting and Removing Your Personal Information
You have the following data protection rights:
To exercise any of these rights, please contact by email at privacy@apkudo.com or by mail to Apkudo, Inc., 3500 BOSTON STREET SUITE #330, MS-48 BALTIMORE MD 21224 USA, Attention: Privacy. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.
If you would like to access or control your data with one of our customers or users of the Subscription Service, please contact the customer or user directly. Apkudo acts as a processor for our customers and will work with our customers to fulfill these requests when applicable.
Anti-Spam Policy
Our Acceptable Use Policy, at http://Apkudo.com/legal/acceptable-use.html, applies to us and to our customers and, among other things, prohibits use of the Subscription Service to send unsolicited commercial email in violation of applicable laws, and requires the inclusion in every email sent using the Subscription Service of an "opt-out" mechanism and other required information. We require all of our customers to agree to adhere to the Acceptable Use Policy at all times, and any violations of the Acceptable Use Policy by a customer can result in immediate suspension or termination of the Subscription Service.
To Unsubscribe From Our Communications
Our customers are solely responsible for their own marketing emails and other communications; we cannot unsubscribe you from their communications. You can unsubscribe from our customers' marketing communications by clicking on the "unsubscribe" link located on the bottom of their emails, or by contacting them directly.
This section applies only to California consumers. It describes how we collect, use, and share California consumers' Personal Information in our role as a business, and the rights applicable to such residents. The California Consumer Privacy Act ("CCPA") requires businesses to disclose whether they sell Personal Data. Apkudo is a business, and does not sell Personal Data. We may share Personal Data with third parties if those third parties are authorized service providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such Personal Data.
If you are unable to access this Privacy Policy due to a disability or any physical or mental impairment, please contact us and we will arrange to supply you with the information you need in an alternative format that you can access.
For purposes of this section "Personal Information" has the meaning given in the California Consumer Privacy Act (“CCPA”).
How We Collect, Use, and Share your Personal Information
We have collected the following statutory categories of Personal Information in the past twelve (12) months:
The business and commercial purposes for which we collect this information are described in Section 2 of this Privacy Policy. The categories of third parties to whom we "disclose" this information for a business purpose are described in Section 3 of this Privacy Policy.
Your California Rights
You have certain rights regarding the Personal Information we collect or maintain about you. Please note these rights are not absolute, and there may be cases when we decline your request as permitted by law.
The right of access means that you have the right to request that we disclose what Personal Information we have collected, used and disclosed about you in the past 12 months.
The right of deletion means that you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions.
The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights.
How to Exercise your California Rights
You can exercise your rights yourself or you can alternatively designate an authorized agent to exercise these rights on your behalf. Please note that to protect your Personal Information, we will verify your identity by a method appropriate to the type of request you are making. We may also request that your authorized agent have written permission from you to make requests on your behalf, and we may also need to verify your authorized agent's identity to protect your Personal Information.
Please use the contact details below, if you would like to:
If you have any questions about this Privacy Policy or our privacy practices, or if you have a disability and need to access this notice in a different format, please contact us at privacy@apkudo.com or by mail :
Rebecca Wright
Apkudo, Inc.
3500 BOSTON STREET SUITE #330, MS-48
BALTIMORE MD 21224
USA
