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Privacy Policy

Last Update: Nov 3, 2023

CAMPAIGNSWELL INC. - 651 N Broad St, Suite 201 Middletown, DE 19709

This privacy policy will explain how CAMPAIGNSWELL INC. (“we”, “us”, “our”, “CAMPAIGNSWELL”) collects and uses the information and data.

This privacy policy applies to: 

  1. Information and data that our customers (“Customer(s)”) provide to us when when they use the services (the ”Services”) under the Terms of Service (the “Agreement”) available at https://campaignswell.com/terms (“Customer’s Data”);

  2. Data about the end users of the Customers’ products including websites and mobile applications that the Customers provide to us in for using the Services (“End Users’ Data”);

  3. Data that we collect when you visit our website https://campaignswell.com/ and all subdomains in https://*.campaignswell.com (“Visitors’ Data”)

The Customer’s Data, the End Users’ Data and the Visitors’ Data is collectively referred to as “Data”.

DATA PROCESSING

Our legitimate interests are: maintaining and managing the Services, providing the Services to you, improving the Services, processing of the information that you choose to provide to us via email or submitting on our website or by using the Services, preventing fraud or harm to us or to any third party, ensuring your account is adequately protected, ensuring the overall security of our network and services, compliance with any contractual, legal or regulatory obligations under any applicable law.

The Customer is the data controller of the End Users’ Data, and we are its data processor. The Customer determines the purposes and means of processing of the End Users’ Data. We only process the End Users’ Data on the Customer’s instructions for the purposes of providing the Services to the Customer.

We are the data controller of the Customer’s Data and the Visitor’s Data.

Customer's Data
Data collected
Purpose of processing
Legal basis for processing

Information that you provide when you use the Services including your professional or employment related information such as full name, email, address, postal code, tax ID, VAT ID, telephone number, company name and position, brand name, country, city.

We use this data to manage and administer the Services provided to you.

We use this data to enable us to fulfil our obligations to you as part of the Services (e.g. in cases where you request restoration of your account).

We may use this information to inform you of any updates to the Services, including new features and functionalities.

Legitimate Interest.

Performance of a contract with you.

Where necessary, a copy of your identity or another document containing your name, surname, photograph, number of the principal identity document of you or your representative, payment details and other additional data, with that you may provide us, including through our support service.

We may take additional verification steps that we consider reasonable in order to verify your account.

We use this data in order to identify you, verify your account and prevent abuse and infringements of your or other persons' rights.

For example, we use this information to verify your identity if you lose your credentials and wish to regain access to your account.

Legitimate Interest.

Performance of a contract with you.

 
End Users’ Data

Your email and the contents of your message you submit via our support email support@campaignswell.com.

We use this information to communicate with you including the response to your inquiries or complaints.

Legitimate Interest.

Performance of a contract with you.

Data collected
Purpose of processing
Legal basis for processing

End user’s engagement information that is related to the ad campaigns and end user actions, such as: clicks on ads, ad impressions viewed, audiences or segments to which an ad campaign is attributed, the type of ads and the webpage or Application from which such ads were displayed, installations of applications, and other interactions, events and actions Licensee choose to measure and analyse within their Application (e.g. app installs, launches, in-app purchases made, clicks, screens transitions, engagement time etc.).

Some of this information may be collected from various advertising networks and third parties that are used in connection with the measurement and analysis of marketing campaigns.

To aggregate the data from media and marketing sources as a part of the Services

Legitimate Interest.

Performance of a contract with you.

Data from mobile measurement platforms.

Device related data: browser type, device type and model, CPU, system language, memory, OS version, screen resolution, time stamp and zone, carrier, location, app version data, installed apps, the Internet provider, the dates and times an end user accesses an application and other similar information. This also refers to various technical identifiers that generally only identify a computer, device, browser or application. For example, IP address (which may also provide general location information), end user agent, network data (MAC address, Wi-Fi and other networks devices have connected to), IDFA (identifier for advertisers), IDFV, Android ID (in Android devices); Google Advertiser ID, Customer issued user ID and other similar unique technical identifiers.

To understand and analyze the conversion rates and other statistics and measurements related to your marketing campaigns.

Legitimate Interest.

Performance of a contract with you.

Data from application stores and payment services. 

Statistics on purchases within our customer’s services or applications and refunds statistics e.g. status of purchases, cancellation of subscriptions, billing issues.

Other events or data as you may instruct this type of third parties to process.

To understand your metrics around subscription, purchases, and refunds and gather real-time statistics on purchases and overall payment behavior in order to render the Services.

Legitimate Interest.

Performance of a contract with you.

 

YOU BEAR THE SOLE RESPONSIBILITY FOR APPROPRIATELY COLLECTING THE DATA UNDER A VALID LEGAL BASIS FROM THE END USERS OF YOUR PRODUCTS (E.G. CUSTOMER’S APPLICATIONS) OR SERVICES. PLEASE READ THE PRIVACY NOTICES AND PRACTICES OF THE RESPECTIVE INTEGRATED THIRD PARTIES CAREFULLY SINCE YOU ARE THE ONE THAT HOLDS RESPONSIBILITY FOR THE PROPER PRIVACY SETTING OF YOUR ACCOUNTS. WE WILL NOT BE LIABLE FOR ANY ACTIONS OR INACTION RELATED TO INVALIDITY OF THE END-USER DATA PROCESSING EVEN WHEN SUCH DATA IS TRANSFERRED TO US TO PERFORM THE SERVICES AS DESCRIBED ABOVE. YOU MUST NOT, IN ANY EVENT, TRANSFER TO US ANY DATA THAT MIGHT BE CLASSIFIED AS SENSITIVE UNDER APPLICABLE LAWS INCLUDING BUT NOT LIMITED TO DATA REVEALING RACIAL OR ETHNIC ORIGIN, POLITICAL OPINIONS, RELIGIOUS OR PHILOSOPHICAL BELIEFS, OR TRADE UNION MEMBERSHIP, GENETIC DATA, BIOMETRIC DATA FOR THE PURPOSE OF UNIQUELY IDENTIFYING A NATURAL PERSON, DATA CONCERNING HEALTH OR DATA CONCERNING A NATURAL PERSON’S SEX LIFE OR SEXUAL ORIENTATION. BY ENTERING INTO AN AGREEMENT WITH US YOU CONSENT TO BE BOUND BY THIS PROVISION OF THE POLICY.

Visitor’s Data
Data collected
Purpose of processing
Legal basis for processing

Technical Information such as browser type, operating system, device type, IP address, country and language settings and other similar information typically received when you visit our website. This may include the referring URL that led you to our website.

We use this information to operate our website, diagnose any problems and to improve the website and your navigating experience.

We also use this information to tailor the content that we may send or display to you on our website, and to otherwise personalise your experiences while using our website.

 

We also use this information to better understand how individuals access and use our Services, both on an aggregated and individualised basis; to respond to their desires and preferences; to improve the products of the Company, its partners and affiliates (including targeted advertising and modelling Internet user behaviour) and for other research, analytical or statistical purposes.

Legitimate Interest.

Usage information collected through your use of the website, such as webpages you access, where you clicked and other similar information related to how you have used our website. This also include web log data, such as dates and times you access our website, IP addresses, event information (e.g., web server responses, system crashes etc.)

We use this information to tailor the content that we may send or display to you on our website, and to otherwise personalise your experiences while using our website.

We also use this information to better understand how individuals access and use our website, both on an aggregated and individualised basis; to respond to their desires and preferences; to improve the products of the Company, its partners and affiliates (including targeted advertising and modelling Internet user behaviour) and for other research, analytical or statistical purposes.

Legitimate Interest.

Information that is automatically received at the time of access to the website through use of cookies, pixels, redirect links, JavaScript tags and other similar technologies.

We use this information to analyse how our website is used and to tailor content that is relevant to you. It also helps us to deliver more relevant advertisements to you on our own or third party websites.

Consent on use cookies.

Information you share voluntarily with us, such as your name and email address when you send us an email asking a question, or submit a form on our website. We will also collect any other Information that you choose to provide to us, such as the contents of a message that you submit through our website.

We use this information to communicate with you, including via email, about our Services; to respond to your inquiries or complaints.

Legitimate Interest.

 

The Customer agrees that CAMPAIGNSWELL may engage Sub-Processors to Process the Data on behalf of the Customer. CAMPAIGNSWELL will remain responsible for each Sub-Processor’s compliance with the obligations of this Policy and for any acts or omissions of such Sub-Processor that cause CAMPAIGNSWELL to breach any of its obligations under this Policy.

 

Sub-Processor
Sub-Processor
Subject matter and nature of Processing Activities
Location of processing

Data and cloud storage solution

US/EU

Data visualisation solution

US/EU

A web infrastructure and website security

US/EU

Data and cloud storage solution

US/EU

DATA SHARING

We will share your data with third parties only as listed below:

  • We will process your data with the assistance of our service providers who assist us with the internal operations of our website and the Services. For example, we engage service providers for data storage, development of the software underlying the Services, and marketing. These service providers are authorised to use your data in this context only as necessary to provide these services to us and not for their own promotional or other purposes

  • We will share your data with competent authorities if you violate the Terms of Service https://campaignswell.com/terms or applicable law.

  • We will share your data with legal parties and advisors helping us handle your violation of the Terms of Service https://campaignswell.com/terms or applicable law.

  • We will share your data if we are legally required to do so.

  • We will share information if we are required to do so by a judicial, governmental or regulatory authority.

  • We will share your data with remarketing services to advertise on third party websites to you after you visited our Services. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Services.

DATA RETENTION

We will implement measures to secure the data in accordance with applicable lawand reduce the risks of damage, loss of data and unauthorised access or use of data.

We will retain your data for as long as we need it for our legitimate interests, in particular, for the performance of the Services or for the compliance with our legal obligations, resolving disputes, establishing and defending legal claims and enforcing our agreements.

When we have no ongoing legitimate interests to process the data, we securely delete the data or anonymize it or, if this is not possible, securely store the data and isolate it from any further processing until deletion is possible.

 

We will retain your data as long as your account is active or needed to provide you Services.

If you choose to deactivate your account or terminate our agreement we will retain your data for a reasonable period in case you decide to re-activate the Services unless you decide to delete your data as specified by the Policy. After the expiration of this period we will aggregate and anonymize all our data (including End-user data) and will only retain it as needed for some of the purposes indicated in the section above.

We may also retain certain categories of your data (excluding any identifiable End-user data) and other information after your account has been terminated or deleted as necessary to comply with legal obligations, resolve disputes, and enforce our agreements.

We take all reasonable and appropriate measures to protect all data we collect from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction.

Among other things, we use the following measures to protect the security of your data:

  • We have limited access to your data internally. Only specific employees in very specific roles may access your data for purely technical and support reasons. All our crew is fully trained to handle personal data and is under confidentiality obligations.

  • We use encryption to protect your data from unauthorized access.

  • We protect your data integrity with various technologies.

  • We maintain high physical, organizational, and legal measures to protect your data.

  • We have other methods to preserve the confidentiality, integrity, and availability of your data (e.g. limiting the number of IP addresses that can access your account).

Please understand that you can help keep your data secure by choosing and protecting your password appropriately, not sharing your password, and preventing others from using your device. Please understand that no security system is perfect and, as such, we cannot guarantee the absolute security of our Services, or that your information will not be intercepted while being transmitted to us. 

If you want to report a security incident related to the Services or the Platform please contact us at info@campaignswell.com.

 

  • Managing database access privileges and imposing restrictions on those with access privileges. This includes maintaining an updated list of users authorized to access the database, according to the various access privileges.

  • Having its staffer who are authorized users of the data importer execute an undertaking of confidentiality and obligations.

  • Employing appropriate security measures, commensurate with the sensitivity of the information, to prevent inadvertent or deliberate system intrusion beyond the scope of a user’s access privileges.

  • Detecting information integrity breaches and handling such breaches.

  • Developing measures to give the data exporter greater control over the various data processing settings.

  • Establishing procedures to have the data deleted from the data importer’s systems at the end of the engagement.

INTERNATIONAL TRANSFER

We will internationally transfer your data in accordance with applicable data protection laws.

We use third-party providers and services to store your data. Some of the servers where your data is stored may be located in counties that may not offer the same protections as the law of your jurisdiction. You consent and authorize us to store your data in such a manner.

We commit to affording your data with the requisite level of protection, e.g. using standard contractual clauses and other available recourse mechanisms.

We may store your data in the USA, Canada, United Kingdom and Germany or other EU country depending on your particular case.

PRIVACY RIGHTS

We are committed to providing you vast privacy rights with respect to your data.

  1. Right to withdraw your consent. If you provided us consent to process some of your data, you may withdraw this consent at any time. Please be informed that as described in the Policy, we rarely or almost never rely on consent to process your data.

  2. Right to object the processing of your data. You can object to the processing of your data if you process under a legal basis for processing other than consent, e.g. legitimate interest.

  3. Right to access your data (including receiving a copy in a portable and (or) readable form). You may request us to provide further details of what data and why is being processed as well as ask us to send you a copy of your data in a portable format. Please note that you may only request your data in a portable format if we process such data based on our contractual obligations or your consent.

  4. Right to delete your data. You may request us to delete certain data. Please note that deletion of some data may make it impossible for you to use our Services. We may also delete some of your End User Data if you instruct us to do so in compliance with our processor’s obligations under applicable laws.

  5. Right to restrict processing of your data. In some cases, you may instruct us to restrict the processing of certain data, e.g. if you think it is inaccurate or incomplete and require correction.

  6. Right to correct or rectify your data. If you believe that the data that we process is inaccurate or not up-to-date, you may request us to correct it.

  7. Right to lodge a complaint. You have the right to bring a claim before your competent data protection authority. However, before doing so let us know first at info@campaignswell.com. We care about your privacy and want to make sure that we do everything to address any of your concerns.

Please note that some laws may require us to perform any other action not specifically mentioned in this section as well as to limit the scope of the exercise. In such cases, we will try to match your request with the highest possible standards prescribed by the Policy but reserve a right to exercise your rights within the limits of the laws that apply to your case.

Also keep in mind that if we receive a vague request, we may engage you to better understand the motivation and content of the request. We may also refuse manifestly unfounded and excessive (repetitive) requests.

PRIVACY OF MINORS

We are committed to protecting the privacy of children. The Services are not intended for children and we do not intentionally collect information about children under 16 years old.

Please contact us at info@campaignswell.com if you become aware that anyone under 16 years old uses the Services and his, her or their data is being processed by us. We will take the required steps to delete such information.  

We undertake to respect any privacy limitations on the processing of minors’ data that apply in your jurisdiction.

You are specifically forbidden to provide us any data that does not comply with this section of the Policy. It is your sole responsibility to make sure no minor data is processed via our Services. Violating such obligations may result in the early termination of our mutual contractual arrangements.

COOKIES AND HOW TO MANAGE THEM

Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. When you visit our website, we may collect information from you automatically through cookies or similar technology.

For further information, visit allaboutcookies.org.

We use cookies in a range of ways, including:

  1. To keep you signed in

  2. To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.

  3. To keep our site safe and secure.

  4. For measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.

  5. To improve our site to ensure that content is presented in the most effective manner for you and for your computer.

  6. To allow you to participate in interactive features of our site and service, when you choose to do so.

  7. To deliver and improve our products and services and your overall user experience.

There are a number of different types of cookies, however, our website uses:

  1. Preference Cookies - we use these cookies so that we recognise you on your website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.

  2. Session Cookies - we use these cookies to operate our Service.

  3. Security Cookies - we use these cookies for security purposes for your account and our service.

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

PRIVACY POLICIES OF OTHER WEBSITES

Our website and application may contain links to other websites. Our Privacy Policy applies only to our website, so if you click on a link to another website, you should read their privacy policy.

CONTACT US

We keep our Privacy Policy under regular review and place any updates on https://campaignswell.com/privacy. This Privacy Policy was last updated on the date set forth at the beginning.

If you have any questions about our Privacy Policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to email us: info@campaignswell.com.

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