Apkudo Product Privacy Terms

Last Modified: 31 March 2021

We at Apkudo (Apkudo, Inc. and the Apkudo affiliates listed in Annex 3 to the Data Processing Agreement) are committed to protecting your privacy. Our Product Privacy Policy applies to your use of the Apkudo Subscription Service as a customer of Apkudo (Apkudo, Inc.). This Product Privacy Policy describes how we collect, receive, use, store, share, transfer, and process your Personal Data. It also describes your choices regarding use, as well as your rights of access and correction of your Personal Data.

This Product Privacy Policy also describes how we process Customer Data on behalf of our customers in connection with the Apkudo Subscription Services. This Product Privacy Policy does not apply to any information or data collected by Apkudo as a controller for other purposes, such as information collected on our websites or through other channels for marketing purposes. Please find the Apkudo Privacy Policy that covers this information or data by clicking here.

Apkudo processes Customer Data under the direction of our Customers and has no direct control or ownership of the Personal Data we process on behalf of our customers. Customers are responsible for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining consent prior to transferring the Personal Data to Apkudo for processing purposes. Terms not otherwise defined herein shall have the meaning as set forth in the Apkudo Customer Terms of Service. In the event of a conflict between this Product Privacy Policy and the Customer Terms of Service, the terms of the Customer Terms of Service will control.

We periodically update this Product Privacy Policy. We will post any changes on this page and, if the changes are material, we will provide an update through the notification app in your Apkudo account.

1. Use of the Subscription Service

A. The Apkudo Subscription Service

Our online Subscription Service allows users (typically connected device industry businesses) to manage various product and lifecycle aspects of connected devices. The information added to the Subscription Service, either by users entering information or when a Subscription Service itself adds the information, is stored and managed on our service providers' servers. Apkudo provides the Subscription Service to our customers for their own device management needs.

To create a user account, we require that a user provide their name, and email address; the user’s employer’s single sign on service will manage the username and password to be used to access the user account. A user’s employer’s systems may return certain information about users to us, including, but not limited to, the user’s full name, title, role, department, physical address, and phone numbers.

B. Use By Our Customers

Our customers use the Subscription Service to manage the complete lifecycle of connected devices for their business. When customers use the Subscription Service, they may process devices that contain the personal information of the previous or current owner of the device. That Personal Data is controlled by them and is used, disclosed and protected by them according to their privacy policies. Apkudo processes our customers' information as they direct and in accordance with our agreements with our customers, and we store it on our service providers' servers.

Our agreements with our customers prohibit us from using that information, except as necessary to provide and improve the Subscription Service, as permitted by this Product Privacy Policy, and as required by law.

We have no direct relationship with individuals who provide Personal Information to our customers. Our customers control and are responsible for correcting, deleting or updating information they have collected from using the Subscription Service. We may work with our customers to help them provide notice to their visitors about their data collection, processing and usage.

2. How we Share Information we Collect

A. With Service Providers

We employ other third-party service providers to provide services on our behalf to 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. Examples may include removing repetitive data records, analyzing data or performing statistical analysis, supplementing the information you provide us in order to provide you with better service, and providing customer service or support. These service providers are prohibited from using your Personal Data 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 customer data handling policies. Examples of these third-party service providers can be found on this page.

B. Due to 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 Data, and choices you may have regarding your Personal Data.

C. In accordance with Compelled Disclosure

We reserve the right to use or disclose your Personal Data 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.

D. Customer Support

We may disclose your information if you request or authorize it or the information is provided to help complete a transaction you have requested.

3. Apkudo Privacy Disclosures

A. Third Parties

We may provide links within the Apkudo portal and services to the sites or services of third parties. We are not responsible for the collection, use, monitoring, storage or sharing of any Personal Data by such third parties, and we encourage you to review those third parties' privacy notices and ask them questions about their privacy practices as they relate to you.

B. Data Practices and Service Data

We automatically collect metrics and information about how Users interact with and use the Subscription Service. We use this information to develop and improve the Subscription Services and the Consulting Services, and to inform our sales and marketing strategies. We may share or publish this service data with third parties in an aggregated and anonymized manner, but we will not include any Customer Data or identify Users.

If you access the Subscription Services via our mobile applications, we may also collect your device model and version, device identifier, and OS version. We may send you push notifications from time to time. If you no longer wish to receive such communications, you may turn them off at the device level.

We use Customer Data in an anonymized manner for machine learning that supports certain product features and functionality within the Subscription Service.

When you use the Subscription Service, we automatically collect log files. These log files contain information about a Users’ IT system, a User’s 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. We use this information to ensure the optimal operation of the Subscription Service and for security purposes. We may link log files to Personal Data such as name, email address, address, and phone number for these purposes.

You can log in to our site using a Single Sign-on (SSO) service. This service will authenticate your identity and provide you the option to share certain Personal Data with us such as your name.

C. Use of Your Information

We may use the Personal Information you provide us or we otherwise receive for our legitimate commercial interests, including:

  • • to respond to your inquiries and to provide you with the information, products and services that you request from us;
  • • to verify that you qualify as a registered user;
  • • to notify you of changes or improvements or upgrades to the Website or the Subscription Service;
  • • where the processing is required in order to enforce or apply our Customer Terms of Service and other agreements you have entered into;
  • • to contact you as necessary including to verify your identity;
  • • to administer the Subscription Service and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • • to improve the Website and/or the Subscription Service and to customize the content you see on either;
  • • to conduct business research and development of new products and services;
  • • to comply with our legal and regulatory obligations or enforce our rights;
  • • to improve customer service and to assist us in identifying ways to provide better service or enhance user experiences with the Website and the Subscription Service;
  • • to promote our Subscription Service and products and services of third parties with whom we deal;
  • • as part of our efforts to keep the Website and the Subscription Service safe and secure including detecting and preventing fraud and unauthorized conduct;
  • • to respond to inquiries and respond to and resolve complaints;
  • • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
  • • to do internal research on our Website visitors’ interests and behaviors to better understand and serve our customers.

4. Data Retention

Customer Data collected during your use of the Subscription Service is retained in accordance with the provisions of the DPA and is retained for as long as you have a paid Subscription and/or remain an active customer in your portal. Your data is deleted upon your written request or after an established period following the termination of all customer agreements. In general, Customer Data is deleted after your paid Subscription ends and your portal becomes inactive.

5. How We Transfer Data We Collect Internationally

A. International Transfers within Apkudo’s Entities

To facilitate our global operations, we transfer information outside of the United States and allow access to that information from countries in which the Apkudo Affiliates have operations for the purposes described in this policy.

This Privacy Policy shall apply even if we transfer Personal Data to other countries. We have taken appropriate safeguards to require that your Personal Data will remain protected. When we share information about you within and among Apkudo’s Affiliates, we make use of standard contractual data protection clauses as referenced in our DPA. We also follow EU-U.S. and Swiss-U.S. Privacy Shield Frameworks to help safeguard the transfer of information we collect from the European Economic Area (EEA), the United Kingdom, and Switzerland.

B. 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 European Economic Area or Switzerland, we make use a variety of legal mechanisms to safeguard the transfer, including the 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.

6. California Residents

A. Your California Privacy Rights

California residents are permitted by California law to request information once a year about the manner in which we share certain categories of information with others for their direct marketing purposes.

We do not share your personal information with third parties for their direct marketing use unless we have your permission. To withdraw permission previously granted please email us at privacy@apkudo.com. Once we receive your instruction, we will cease sharing your information, but this will not affect previously shared information.

Under the California Consumer Privacy Act (the “Act”) California residents have the right to know what personal data we have collected about them including the right to receive a copy of the specific data collected about them during the prior 12 months, the right to have their personal data deleted to the extent it is not within an exception under the Act , the right to know what personal data is sold or disclosed to third parties, and the right to have such data not shared with third parties. To make a request for one of the foregoing disclosures, which may be made twice in 12 months, please either email us at privacy@apkudo.com. You will be required to provide information or documentation to verify your identity before we can process your request.

7. Privacy Framework

Apkudo, Inc. is committed to the Frameworks' applicable principles regarding transfers of Personal Data received from the European Economic Area (EEA), the United Kingdom, and Switzerland. To learn more about the Privacy Shield Frameworks, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov.

Apkudo is responsible for the processing of personal data it receives under each Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. Apkudo complies with the Privacy Shield 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 Shield 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.

8. Accessing Your Information

A. Accessing Your Personal Information and Your Choices

If your Personal Information changes, or if you no longer desire to have access to or use of the Service, you may contact Apkudo at help@apkudo.com to update your information or to cancel your user account. We will require that you provide information or documentation to verify your identity before making any changes. You can choose to stop receiving promotional emails from us by following the opt-out instructions in any email you receive. This will not stop us from sending emails to you about your account or your transactions.

You can choose to delete or block cookies by adjusting the settings on your browser. If you block cookies, performance of the Website may be impaired and certain features may not function.

9. Contact Us

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 #210, MS-48
BALTIMORE MD 21224
USA