Last Updated: June 17, 2015
Information We Collect
Non-Personally Identifiable Information
When you sign up and/or use our Service, our servers may record, collect and store the following non-personally identifiable information: (i) if you are accessing our Service through the Site, your IP address, browser type, a non-personal identifier for your device and other general information about visitors to the Site; (ii) if you access the Service through the Mobile Software, information that your mobile phone/device sends or transmits, including your device type and identifier (including but not limited to IMEI, SerialId, and/or MAC provided that such information does not allow your personal identification), and user settings; (iii) certain non-personally identifying information and record information provided by you when you register for the Service or through your use of the Service, such as gender or date of birth or a non-personal identifier for your device; (iv) information about or from another content delivery platform (for example, to unlock potential rewards or offers based on your watching of a specific advertisement or filling out surveys); (v) information about the applications installed on the device, including the last time they were run, the last time they were installed/updated, and the amount of data they have consumed since restart of the device, as well as the last time the device was restarted; and (vi) information derived from the above-mentioned information and other sources, such as entries and offers provided by Affiliated Service Partners (together, "Non-Personally Identifiable Information"). "Affiliated Service Partners" means third party advertisers and other third parties that provide or make available the advertisements and advertising offers through the Mobile Software that allow you to earn data credits.
We may use "cookies" to collect information. A cookie is a small data file that is transferred to your computer's or mobile device’s storage for record-keeping purposes. We may use utilize persistent cookies to monitor users’ interaction with advertisements and advertisement offers made available to earn data credits. If cookies are used, we use these cookies to (i) automatically login users to the Site and the Mobile Software, (ii) identify when a user has clicked on an offer, (iii) identify which offer was clicked on by a user, (iv) confirm when the action required by an advertising offer has been completed, (v) determine your eligibility for the Service, and (vi) identify user hardware for purposes of network integration.
Affiliated Service Partners and other third party advertisers on the Site and the Mobile Software may also place or read cookies. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Service.
Personal Information You May Provide To Us
When you use our Service, we may ask that you provide us with some personally identifiable information which is information about you that can be used to contact or identify you, and information on your use of the Service and related services ("Personal Information"). Personal Information that we might collect may include data such as your name, mobile telephone number, other phone numbers, email address, or postal code. Personal Information may also include other information you supply to us, through an "opt-in" mechanism, concerning your preferences and interests expressed in the course of using the Service.
When you access our Service through the Mobile Software, Aquto may ask you for permission to collect and use real time location data. We will not store this data. However, you can choose not to share your location information with us, including by using the settings and other controls on your mobile device. If you turn off your location data you may not be able to use all portions of the Service.
When you access the Service through our Mobile Software, you may also be asked to allow push notifications, text messages, alerts, emails or other types of messages directly sent to you outside or inside the Service ("Push Messages") to be sent to you outside or inside of the Mobile Software. If you do so a device token will be generated, which is associated with you until you log out. We will collect and store these device tokens on our servers.
Information Provided to Us by Third Parties
We may also receive Personal Information from your mobile operator such as your mobile telephone number, whether or not your mobile device is eligible to use the Service, the billing account identifier and the balance and end date for your mobile account.
If you register for the Service through certain third party services such as Facebook Connect or Google ("Reference Site") we may receive certain Reference Site account information, such as email address, your name, language and country, and other necessary information to provide you with the Service. By using a Reference Site, you are allowing us to access your account information related to the Reference Site.
We may also receive Personal Information from Affiliated Service Partners provided by you in the course of your using their services, or from third parties (e.g., white pages listings providers), subject to the limitations of the Privacy Policies of those Affiliated Service Partners or third parties.
If you do not wish to have your Personal Information collected by these methods, you may not be able to earn and redeem data credits through the use of the Service.
How Do We Use the Information?
We use Personal Information only for the following purposes: (i) to administer the Service, (ii) to provide, improve and optimize the Service, (iii) to personalize your experience, (iv) to provide you with software updates and/or product announcements, (v) to better understand users’ needs and interests, and (vi) to provide you with further information and offers from us that we believe you may find useful or interesting, such as targeted advertising and promotional campaigns. In the event any of your Personal Information needs to be used for a purpose other than as described above, you will have the opportunity to limit such use through an "opt-out" mechanism.
We may request personal information for special events such as a sweepstakes or contests and, in that event, you will have the right to opt out of participation if you do not wish to have your personal information collected for that purpose. Furthermore, we will disclose in the information or rules related to such special event how we intend to use your personal information.
Non-Personally Identifiable Information
We may use Non-Personally Identifiable Information for a few purposes. We may analyze trends through aggregated demographic and psychographic information about our users generally, to improve features and functionality of the Service and to make more relevant offers to users and to provide awards to users. We may also share this Non-Personally Identifiable Information (including real time location data if users have enabled or allowed location features on their mobile device) with our Affiliated Service Partners to allow them to assist us in delivering tailored advertisements, promotions, sweepstakes, discounts, and other incentives to you when you use the Service. Any information shared with Affiliated Service Partners in this context will not contain nor be linked to your Personal Information unless you have given us your explicit consent through an "opt-in" mechanism through the Mobile Software. For example, an Affiliated Service Partner may want to test advertisements of its products to a certain audience (for example, men ages 18-34) or audience segment (for example, women ages 25-40 who have viewed certain content). If the Non-Personally Identifiable Information that we have collected about you meets this description, you would be able to participate in the Affiliated Service Partner offer(s).
We collect and analyze statistics regarding user viewing and usage of incentives provided by Affiliated Service Partners for the purpose of improving the Service. We may provide third parties with our analysis or aggregated statistics consisting of Non-Personally Identifiable Information so that they may improve their services. We do not track users outside the Service.
When Do We Share Information?
We will not share your Personal Information with anyone else except when we otherwise have your permission, or under the following circumstances:
Non-Personally Identifiable Information
We may share Non-Personally Identifiable Information with Affiliated Service Partners to perform the Service to allow them to assist us in delivering tailored advertisements, promotions, sweepstakes, discounts, and other incentives to you when you use the Service. This may include real-time location data for users that have enabled or allowed location features on their mobile device. Any information shared with Affiliated Service Partners in this context will not contain nor be linked to your Personal Information unless you have given us your explicit consent through an "opt-in" mechanism through the Mobile Software. Also, we may share aggregated information in a form that does not disclose your Personal Information, nor be reasonably likely to allow you to be personally identified, for industry analysis, demographic profiling and similar purposes. We share this aggregated information so that our Affiliated Service Partners understand how interested our users are in their products and services.
Service Providers or Agents
We may employ or partner with third party companies and individuals to process your payments, facilitate our Service, to provide all or a portion of Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is being used. These third parties may have access to your Personal Information but only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. In any case, Aquto shall remain responsible for the data processing of your Personal Information.
Compliance with Laws and Law Enforcement
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We reserve the right to track IP addresses for the purposes of fraud prevention, and to release IP addresses to legal authorities. We will disclose information about you to government or law enforcement officials or private parties to the extent necessary to comply with law, to protect our property and rights or those of a third party to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.
Retention of Personal Information
If we have your Personal Information, we will retain it for up to 60 days after you terminate your account, unless a longer retention period is required or permitted by law.
Security of Information
We employ administrative and electronic measures and procedures according to generally accepted Internet and wireless industry standards designed to safeguard and protect your information from unauthorized access and disclosure. At a minimum, all communication between the Mobile Software and its backend infrastructure are authenticated and encrypted using generally accepted security practices (e.g. the SSL protocol). Information retrieved from your mobile operator regarding the details of your data plan is only retrieved on an "as needed" basis when the Mobile Software is accessed for the purpose of supporting its functionalities.
It is important for you to protect against unauthorized access to your wireless device and to the Mobile Software.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on the Service consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Information You Can Access; Ability to Opt-Out
Examples of information you can access easily in the Mobile Software include up-to-date information regarding recent Kickbit account activity; as well as Personal Information (including name, mobile telephone number, e-mail, password). You may access, update or remove Personal Information by using the Service or by contacting firstname.lastname@example.org.
You have control over the Push Messages settings, and can opt in or out of these Push Messages through the Service or through the phone’s operating system (with the possible exception of infrequent, important service announcements and administrative messages).
Be advised that if you remove information required to access the Service (your mobile telephone number, email and/or password), you may no longer be able to use the Service.
Links to Affiliated Service Partners and Other Third Parties
The Service is not directed to children. We do not knowingly collect personally identifiable information from subjects under 13 years of age. In any case, where consent by the data subject is required and the subject is below 13 years of age, verifiable parent consent shall be requested. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, please contact us at email@example.com. If we become aware that a person under the age of 13 has provided us with Personal Information without verifiable parental consent, we will delete such information from our files.
Safe Harbor Program
Aquto complies with the US-EU Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Aquto has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view our certification page, please visit www.export.gov/safeharbor.
320 Congress Street
OR via e-mail: firstname.lastname@example.org
Aquto has further committed to refer unresolved privacy complaints under the US-EU Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Aquto, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.
320 Congress Street
OR via e-mail: email@example.com