This Notice supplements our Privacy Policy and describes how Apptad Inc. and its affiliates (“Apptad”) process personal data of individuals located in the European Economic Area (“EEA”), the United Kingdom, and Switzerland (collectively, the “European Region”), in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679), the UK GDPR, and the Swiss Federal Act on Data Protection (collectively, “GDPR”).
1. Data controller
Unless otherwise specified in a separate agreement, Apptad Inc. is the controller of personal data collected through this Site. For specific engagements where Apptad processes personal data on behalf of a customer, Apptad acts as a processor and the customer is the controller.
2. Lawful bases for processing
We process personal data on the following lawful bases:
- Consent — for marketing communications, optional cookies, and other activities you opt in to. You may withdraw consent at any time.
- Contractual necessity — to perform a contract with you (or take pre-contract steps at your request), for example responding to a proposal request.
- Legitimate interests — to operate, secure, and grow our business, including business development, service improvement, and fraud prevention, where these interests are not overridden by your rights and interests.
- Legal obligation — to comply with applicable laws, regulatory requirements, and lawful requests by public authorities.
3. Your rights
If you are in the European Region, you have the following rights regarding your personal data:
- Access — request a copy of personal data we hold about you.
- Rectification — ask us to correct inaccurate or incomplete data.
- Erasure — ask us to delete your data, subject to certain exceptions.
- Restriction — ask us to limit how we process your data.
- Portability — receive your data in a structured, commonly used, machine-readable format.
- Objection — object to processing based on legitimate interests, including for direct marketing.
- Withdraw consent — at any time, where processing is based on consent.
- Lodge a complaint — with the data protection authority in your jurisdiction.
How to exercise your rights
To exercise any right, contact us at privacy@apptadinc.com. We will verify your identity before responding and will reply within one month, with the possibility of a two-month extension for complex requests, as permitted by GDPR. We will tell you within one month of your request if we extend the response period and why.
4. International transfers
Apptad has operations in multiple regions, including the United States, India, and Brazil. When we transfer personal data out of the European Region, we use appropriate safeguards required by GDPR, including:
- European Commission Standard Contractual Clauses (and the UK International Data Transfer Addendum where applicable).
- Adequacy decisions, where available.
- Other lawful transfer mechanisms permitted by applicable law.
You may request a copy of the safeguards applied to a specific transfer by contacting privacy@apptadinc.com.
5. Data retention
We keep personal data only for as long as necessary for the purposes described in our Privacy Policy or as required by applicable law. When we no longer need the data we securely delete or anonymize it.
6. Automated decision-making
We do not make decisions based solely on automated processing — including profiling — that produce legal or similarly significant effects on you.
7. Supervisory authority
If you believe our processing of your personal data infringes the GDPR, you have the right to lodge a complaint with your local data protection authority. A list of EU authorities is available at edpb.europa.eu; the UK authority is the Information Commissioner's Office at ico.org.uk.
8. EU / UK Representative
Where required, Apptad will appoint a representative in the European Region under Article 27 GDPR. Contact details for our representative will be added here once finalized. Until then, please contact privacy@apptadinc.com directly.
9. Contact
For any GDPR question or to exercise a right, email privacy@apptadinc.com.