গোপনীয়তার নীতি

1. 1. Introduction

   1. Welcome to the Aptoide’s privacy notice.
   2. Aptoide respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website and our Android Marketplace Applications (“Aptoide Apps”), regardless of where you visit it from, and tell you about your privacy rights and how the law protects you.

2. 2. Important information and who we are

   1. Aptoide, S.A., a Portuguese company, with the identification number ID 509987184 and principal place of business at Rua Soeiro Pereira Gomes, Lote 1, 3D, 1649-031 Lisboa, Portugal is the controller and responsible for your personal data (collectively referred to as Aptoide, “we”, “us” or “our” in this privacy notice).
   2. This privacy notice aims to give you information on how Aptoide collects and processes your personal data through your use of this website and our Aptoide Apps, including any data you may provide through this website when you use our website or our Aptoide Apps, create a user account, sign up to our newsletter or purchase a product or service.
   3. This Privacy Policy applies to all of our Services unless specified otherwise. Please also read Aptoide's Terms of Service ("Terms"), which describes the terms under which you use our Services.
   4. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

   5. Contact details

      1. Aptoide S.A.
      2. Data Privacy Manager
      3. personal-data@aptoide.com
   6. You have the right to make a complaint at any time to the Portuguese Data Protection Commission (CNPD), the Portuguese supervisory authority for data protection issues (www.cnpd.pt). We would, however, appreciate the chance to deal with your concerns before you approach the CNPD so please contact us in the first instance.

3. 3. Third-party links

   1. Our website and Aptoide App may include links to third-party websites, App Stores, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website or Aptoide Apps, we encourage you to read the privacy notice of every website or app you use.

4. 4. The data we collect about you

   1. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
   2. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
   3. Indentity data: name, email address, date of birth, address, phone number, IP address
   4. Financial data: PayPal account, Credit Card data, APPC wallet address
   5. Transaction data: includes details about payments to and from you and other details of products and services you have purchased from us or from our Partners Apps.
   6. Technical data: includes internet protocol (IP) address, unique device identifier, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our services.
   7. Profile data: includes your username, purchases or orders made by you, your interests and preferences.
   8. Usage data: includes information about how you use our website, mobile apps, products and services.
   9. Marketing and Communications data: includes your preferences in receiving marketing from us and our third parties, your Google Advertising ID (if you have one) and your communication preferences.
   10. Aggregated data: we also collect, use and share Aggregated data, such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
   11. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
   12. IF YOU FAIL TO PROVIDE PERSONAL DATA where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to provide you the services or to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

5. 5. How is your personal data collected

   1. We use different methods to collect data from and about you including through:
   1. Direct interactions.You may give us your Identity and Financial Data by filling in forms or by corresponding with us by email or otherwise. This includes personal data you provide when you:
   1. apply for our products or services;
   2. create an account on our website or Aptoide Apps;
   3. subscribe to our service or publications;
   4. request marketing to be sent to you;
   5. give us some feedback.
   2. Automated technologies or interactions. As you interact with our website or the Aptoide App, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
   3. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out:
   1. Technical Data from the following parties:
      1. analytics providers, based in the EU and outside the EU;
      2. advertising networks based in the EU and outside the EU; and
   2. Contact, Financial and Transaction Data from providers of technical, payment and delivery services based in the EU and outside the EU.

6. 6. How we use your personal data

   1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
   1. Where we need to provide you the services or to perform the contract we are about to enter into or have entered into with you.
   2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
   3. Where we need to comply with a legal or regulatory obligation.
   4. Where you have given to us your consent to use your personal data. Whenever we need your consent to proceed with any usage of data, we will collect it. You have the right to withdraw consent to marketing at any time by Contacting us.

7. 7. Purposes for which we will use your personal data

   1. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
   2. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

   3. Purpose/Activity	Categories of data	Lawful basis for processing including basis of legitimate interest
      To register you as a new user	Identity Contact	Provision of services to you.
      To process and deliver your purchases including: Manage payments, fees and charges. Collect and recover money owed to us.	Identity Contact Financial Transaction Marketing and Communications	Performance of a contract with you. Necessary for our legitimate interests (to manage our relationship with our Partners providing the good, to study how users use our products/services).
      To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy. Asking you to leave a review.	Identity Contact Profile Marketing and Communications	Provision of services to you. Necessary to comply with a legal obligation. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
      To send you marketing or other communications (e.g. newsletters)	Identity	Your consent.
      To administer and protect our business and our website and Aptoide Apps (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	Identity Contact Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise). Necessary to comply with a legal obligation.
      To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.	Identity Contact Profile Usage Marketing and Communications Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
      To use data analytics to improve our website, Aptoide apps, products/services, marketing, customer relationships and experiences.	Technical Usage	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
      To make suggestions and recommendations to you about goods or services that may be of interest to you.	Identity Contact Profile Usage Technical	Necessary for our legitimate interests (to develop our products/services and grow our business).

   4. Marketing

      We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms.

      1. PROMOTIONAL OFFERS FROM US
      2. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
      3. You will receive marketing communications from us if you have requested information from us or purchased goods from our Partners Apps, and, in each case, you have not opted out of receiving that marketing.
      1. THIRD-PARTY MARKETING
      2. We will get your express opt-in consent before we share your personal data with any company outside the Aptoide group of companies for marketing purposes.
      3. Please note that the collection of your personal data by these third parties is exclusively made by way of cookies.
      1. OPTING OUT
      2. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by Contacting us at any time.
      1. COOKIES
      2. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie policy.
      1. CHANGE OF PURPOSE
      2. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.
      3. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

8. 8. Disclosures of your personal data

   1. 1. We may share your personal data with data processors to allow us to provide you with our services. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our processors to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
      2. We also use cookies in our website which allow third parties, including Facebook, to use cookies, web beacons, and other storage technologies to collect or receive information from our websites and elsewhere on the Internet and use that information to provide measurement services and target ads.
      3. The categories of third parties having access to your personal data are the following:
      1. Service providers, based in the EU and outside the EU, acting as processors, to provide us with the following services:
         1. Hosting, provided by, namely, Leaseweb and Amazon;
         2. Security, provided, namely, by Cloudfare;
         3. Analytics, provided by, namely, Google, Hotjar and Facebook Ireland;
         4. Payment processing, provided by, namely Adyen and Paypal;
         5. Log-in to our services using third-party credentials, provided by, namely, Facebook Ireland and Google.
      2. Recipients of your personal data, namely Facebook Ireland and Google LLC, who use cookies to collect or receive information from our websites and elsewhere on the Internet and use that information to provide measurement services and target ads.
      3. Regulators and other authorities who require reporting of processing activities in certain circumstances.
      4. Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

9. 9. International transfers

   1. Some of our data processors are external third parties which are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA which may not be regarded as providing the same level of protection as the jurisdiction you are based in.
   2. Safeguards for international transfers of personal data: In cases where we need to transfer personal data outside the EEA, we will ensure that the following adequate safeguards, as required by applicable data protection laws, are implemented to ensure a similar degree of protection is afforded to it:
   1. Where we use certain suppliers or service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe, known as the European Commission’s Standard Contractual Clauses. For further details, see European Commission: Model contracts for the transfer of personal data to third countries (https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en).
   3. Please Contact Us if you want to obtain a copy of the specific mechanism used by us when transferring your personal data out of the EEA or if you want further information on them.

10. 10. Data Security

    1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
    2. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
    3. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11. 11. Data retention

    1. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
    2. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
    3. In some circumstances you can ask us to delete your data. We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
    4. If you want further information about details of retention periods for different aspects of your personal data you can contact us.

12. 12. Your legal rights

    1. Under data protection laws in relation to your personal data you are entitled to exercise the following rights:
       1. Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
       2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
       3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
       4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
       5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
       6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
       7. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
    2. If you wish to exercise any of the rights set out above, please Contact us.
    1. NO FEE USUALLY REQUIRED
    2. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
    1. WHAT WE MAY NEED FROM YOU
    2. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
    1. TIME LIMIT TO RESPOND
    2. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.