[Last Amended: September 06, 2023]
B. Policy Amendments
C. Controller Information
D. Data Processed by Us
E. Data Collection Methods
F. Data Sharing
G. Cookies and Tracking Technologies
H. Eligibility Age
I. Third Party Links
J. Security Measures
K. Retention of Personal Data
L. Transfer of Data
M. Data Rights for EEA and UK Users
O. Contact Us
Exhibit A. CCPA Privacy Exhibit
Embee Mobile Inc. (a subsidiary of Similarweb Ltd is for the purposes of the EU General Data Protection Regulation (Regulation 2016/679) (“GDPR”) and the UK data protection laws, the Controller of the personal data that processed by it related to Visitors and Users.
You can contact our Data Protection Officer directly at: DPO@Embeemobile.com .
In the event that you are a California resident, you may be subject to the California Consumer Privacy Act (“CCPA”). We encourage you to review our CCPA Privacy Exhibit attached hereto as Exhibit A to learn more about our privacy practices applies to California residents.
Depending on your interaction with us, we may collect two types of data from you:
For the avoidance of doubt, any Non-Personal Data that is connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists. Additionally, please be advised that you are not required by law to provide us with any of your information and you may choose at your discretion to refrain from providing us with certain types of Personal Data.
We will only collect, use and share your Personal Data where there is an appropriate legal basis to do so. below, we have outlined the legal bases upon which we rely, which will impact your rights regarding your Personal Data.
Data Processed from Users:
Types of Personal Data
Purpose of Processing and Lawful Bases
When you download and sign up for our App either directly or via your social media account (i.e., Google or Facebook), you will need to provide us with your full name, date of birth, and Email address.
We will use this information to provide you with our Services as well as to operate, maintain and manage our Services, in order to fulfill our contract with you and subject to our Terms and Conditions.
We may also use your email address you provided us during the registration process in order to send you messages regarding our Services and updates to our Services (“Direct Marketing”).
Direct Marketing is based on our legitimate interest, you may opt-out at any time through the "unsubscribe" link within the email or by contacting us directly.
It is important to note, that even if you choose to unsubscribe from these marketing messages, we may still retain your contact information in order to send you service-related messages.
Demographic Survey and Market Research Surveys:
Demographic Survey: In order to participate in one of our Panels and the Market Research Surveys you will need to fill out a Demographic Survey where you may need to provide us with the following information as shall be determined from time-to-time and reflected in the Survey: exact date of birth, age, gender, date of birth, postal code, education level, ethnicity, household income, occupational status, number of people in your household, if you have children under the age of 18, preferred language for media consumption, preferred spoken language (“Demographic Data”). We store and keep this data to offer you relevant Market Research Surveys so you can earn more Points.
Market Research Surveys: based on the Demographic Survey, and other information we have on you, we may offer you to participate in a Market Research Survey. A Market Research Survey is provided by third party partners, either through a direct survey in which you will be required to respond to various questions and provide the information manually (“Direct Survey”), or an automated survey in which we will collect certain information automatically through technical means (API, SDK) subject to the Permissions you enable (as detailed below) (“Automatic Survey”). For Direct Survey, the Personal Data we process is a generated unique identifier associated with the Direct Survey. We are not aware of or have access to the content or information provided through or in the Direct Survey.
The Personal Data processed through the Automatic Survey is further detailed in the next section under “Permissions”.
The Demographic Data is considered Sensitive Data and shall be processed based on your explicit consent, which can be withdrawn at any time.
We process the unique identifier generated and associated with your response for our legitimate interest in calculating payments or Points, as applicable and detecting fraud.
The Demographic Data is processed (a) in order to assess a User’s Panel eligibility, to ascertain whether a User will meet the target audience for a Market Research Survey; and (b) in an aggregated anonymized manner for our market research, enabling the User to earn Points.
Survey Registration and Survey Data:
The Survey data, includes, depending on the Permissions granted by the User, the following: browsing data, browsing history, the URLs you have viewed, click stream data (collectively “Browsing Data”), your use of other apps on your device such as the duration, frequency, last time an app was used, battery usage, the content you view within the app, etc. (“Usage Data”) including the list of installed apps, and precise location.
The Survey Data is collected through Android App permissions and iOS App permissions (collectively, “Permissions”) or through SDK, as applicable and detailed below.
Permissions available through the Android App (“Android Permissions”): In order to participate in one of our Panels or Survey, a User will need to activate the following Permissions: (i) Location permission, which will provide us with your precise physical location (“Location Permission”); (ii) Accessibility permission, which will provide us with your Browsing Data “Accessibility Permission); and (iii) App Activity Usage permission which will collect the Usage Data (“Usage Permission” respectively).
Collectively these data sets detailed herein shall be referred to as “Android Permission Data”.
Permissions available through the iOS App (“iOS Permissions”): In order to participate in one of our Panels or Survey, a User will need to activate the following Permissions: (i) Location Permissions which will provide us with your precise location (“iOS Location Permission”); (ii) App Tracking Permission which will allow us to collect your Advertising ID (IDFA) (“App Tracking Permission”); and (iii) VPN Permission which allows us to collect Browsing Data and Usage Data.
Collectively these data sets detailed herein shall be referred to as “iOS Permission Data”.
Some of the Personal Data that is collected at this stage may be categorized as sensitive data under some data protection and privacy laws. We will therefore obtain your explicit consent for the processing of such data if we are required to do so under applicable law.
The information collected during the Survey registration process its anonymized, aggregated form, for various market research and business purposes as well as for fraud prevention and in order to improve our Services. These purposes are our legitimate interest in enhancing our research and services while keeping Users fundamental rights, as no Personal Data is used for this purpose.
The list of installer apps, the Android Permission Data and the iOS Permission Data is processing in order to participate in Market Research Surveys and is used for the following purposes:
Market research on brands and products, marketing campaigns, advertising efficacy and investment research; and
We will process Android and iOS Permission Data upon User’s consent and solely if the User wants to participate in the Surveys or Panel and earn more Points. Prior to activating each Permission, we will explain which data sets are processed through such Permission and the purpose of use. Each Permission is provided separately, and you can decide to either accept them all, or accept some or none of them, this will affect the Points you earn, however, will not affect the use of the App.
The Location Permission will also be processed on the basis of our legitimate interests to detect fraud, for authentication purposes, such as determining the User is an actual human, that the phone is the User’s own personal device.
We may use the Usage Data or Browsing Data and list of installed apps to create solutions as part of Embee's market intelligence services in an aggregated anonymized way based on our legitimate interest.
Redemption of Point:
As part of the Services and in order to redeem your Points (as further explained in the Terms),you may need to provide us with additional information such as your email address, bank account or physical address to which you wish to receive the gift.
This information will be processed by us in order to perform our contract with you and to provide you with the gifts you have earned while using the Services.
App Usage Data:
When you install the App or use the App's Services , we will collect and store certain usage data, such as, access logs (time stamp), duration, frequency, the Permissions you enabled, how many Survey or Panel you attend, if there were any crashes or errors, Wi-Fi connection, etc.
We will process this information subject to our legitimate interest for various purposes such as providing the Service, fraud prevention, improving the Services, fixing errors, personalizing the Service, etc.
Device and Browser ID; Technical Non-Personal Data:
We may process your Device ID when you access or use our App or Services.
Additionally, as explained above, we may collect certain types of Non-Personal Data from you when you access or use our App or Services.
We will use this information in order to operate, provide, maintain and manage our Services. Furthermore, some of this information will be processed subject to our legitimate interests for various purposes such as perform research, conduct analytics and statistical activities, detect fraud, etc. Such processing in our legitimate interest will be carried out in a proportionate manner.
Depending on the way you interact with us, we may collect data from you in the following ways:
We will not share any of your Personal Data with a third party, except as stated under the following circumstances, which is required in order to provide our Services:
We use “cookies” (or similar tracking technologies) when you access our App. A “cookie” is a small piece of information that a app assigns and stores on your computer when you access the Website. Cookies can be used for a variety of different purposes, including, allowing you to navigate between pages efficiently, enabling the automatic activation of certain features, remembering your preferences and making the interaction between you and our Website quicker and easier, to prevent fraud and protect our Services. For further information, please contact us at email@example.com .
Please visit: www.allaboutcookies.org to learn more about cookies.
We use the following cookies, third-party tracking or analytic technologies on our App:
Type and Purpose
Analytical, Measurement and Performance
Functional, Operational and Security: We will use firebase for authentication purposes.
Analytical, Measurement and Performance
Analytical, Measurement and Performance
Essential, Functional, and Operational
Functional, and Operational
Our Services and App may contain links to third party services or websites that are not operated by us. These links are offered for convenience and should not be interoperated as an endorsement of the activities or content available on these websites, nor should they imply any affiliation with their operators. Embee holds no responsible for the privacy policies or practices of any third party including, without limitation, websites directly linked to our Services and App (including any of the brands participating in our cash back program). We strongly recommend that you review the privacy policies of any such third-party websites or services before using them.
Embee has implemented reasonable industry standard technical and organizational measures to safeguard the confidentiality, security and integrity of User's Personal Data and thereby preventing any unauthorized use of such Personal Data. Furthermore, we restrict access to User's Personal Data on our servers. The collected data is stored mainly on Amazon Web Services (AWS) servers located in the United States and in the UK. For further details about the security and privacy standards of Amazon, please refer the following link: https://aws.amazon.com/privacy/.
If you have concerns about how your privacy has been handled, please contact us at: DPO@Embeemobile.com . We will make reasonable efforts to notify you or any applicable supervisory authority, where required under applicable laws, in the event that a security incident occurs in which your Personal Data may be at risk.
We may store and process your Personal Data in various locations, including the UK, the EU, the United States or in other countries. consequently, it is important to note that any information you provide us may be transferred to and processed in countries different from the country where you accessed our Website or App. We are committed to implementing appropriate measures to ensure that your Personal Data receives an adequate level of data protection while it is being transferred.
When Personal Data collected within the European Economic Area (“EEA”) or the UK is transferred outside the EEA or the UK (as applicable), we will take necessary steps to guarantee sufficient safeguards during the transferring of such Personal Data. You may, where applicable, exercise your rights to receive information about the specific transfer mechanism employed during the transfer of your Personal Data.
For Personal Data transferred outside of the EEA to a country which has not received an adequacy decision from the European Commission (“Adequacy Decision”), we will perform the transfer in accordance with the standard contractual clauses approved by the European Union (“Standard Contractual Clauses”). Personal Data that we transfer outside of the UK to a country that is not in the EEA, has not received an Adequacy Decision or an adequacy regulation has not been passed regarding it by the UK will be transferred, depending on the situation, either pursuant to the International Data Transfer Agreement or the addendum to be used with the Standard Contractual Clauses, both as issued by the UK’s Information Commissioner.
Depending on your jurisdiction, data protection and privacy laws may provide you with the ability to exercise certain rights with respect to your Personal Data. We have outlined below the rights applicable to residents of the EEA and UK for your convenience. If you are a California resident, please refer to our CCPA Exhibit for information on your privacy rights.
To exercise any of the rights mentioned above, please contact us at: DPO@Embeemobile.com . Alternatively, you can independently exercise certain right through the App settings, such as correcting, accessing, reviewing, and deleting your account information which includes the Sign Up information and the Demographic Data, you can delete your account data from the App settings (removing the App does not delete the account data, you need to first request deletion account and then remove the App), you can opt-out from direct marketing and tracking at any time as detailed above, etc.
We may request reasonable evidence in order to verify your identity before providing you with requested information, subject to applicable law. We aim to respond to a verifiable request without undue delay and in any event in accordance with applicable law. If additional time is needed to fulfill your request, we will notify you in writing, stating the reason and duration of the extention. Our response may also explain the reasons why we cannot fulfill your request, if applicable. When you request to exercise your data portability right, we will provide your Personal Data in a format that is able to be used and that would allow you to easily transmit the information from one entity to another.
M. Contact Information
By email at: DPO@Embeemobile.com
CCPA PRIVACY EXHIBIT
To learn more about your California privacy rights, please visit https://oag.ca.gov/privacy/privacy-laws.
When you access our Website and use our App or Services, we collect certain information with respect to such use and access. This data may include “Personal Information” which is defined under the CCPA as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer, household or device as specified in the table below.
The following table specifies the categories of Personal Information that we may collect (or may have collected within the last 12 months):
Examples of Personal Information
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, address, telephone number, insurance policy number, education, employment, employment history.
Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
G. Geolocation data.
Physical location or movements.
In the preceding twelve (12) months, the Company has disclosed the following categories of Personal Information for a business purpose:
We disclose your Personal Information for a business purpose to the following categories of third parties: service providers (e.g., servers etc.), business partners (e.g., our Partners), affiliates of Embee and third parties to whom you authorize us to disclose your Personal Information in connection with our Services.
in the last twelve (12) months we have sold the following types of Personal Information of users who choose to participate in a Study or take part in a Demographic Survey or a Market Research Survey:
In case you wish to opt-out of the “sale” of the above categories of information, you can send us a Do Not Sell My Personal Information request at any time here or by emailing us at: DPO@Embeemobile.com .
We may make available certain programs or offerings that are considered “financial incentives” under the CCPA. You can find a description of these programs and our applicable notice required by the CCPA here.
You have the right to request the following information from us with regarding the Personal Information we have collected about you in the preceding 12 months (you can make such requests twice per year, subject to specific exemptions):
Subject to certain conditions and exceptions, you may have the right to request deletion of Personal Information that we have collected about you.
If you are a registered user of the App in California and are under 18 years of age you may request the removal of content or information you posted on via the App. We will comply with such removal requests when we are required to do so by law. To request the removal of content or information you posted on the App, you may contact us as described below. Please note that even if we remove the content or information that you posted, we cannot prevent further use or disclosure of that content or information by others once you have shared it publicly.
You may submit a request to us to opt-out of “sale” by visiting our Do Not Sell My Personal Information page and submitting a request there or by emailing us at DPO@Embeemobile.com .
We will not discriminate against you for exercising any of the rights described in this section.
You may exercise any or all of your rights in relation to your Personal Information by contacting our DPO at: DPO@Embeemobile.com or by contacting our support team at: firstname.lastname@example.org . Your request will be examined based on your relationship with us.