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Privacy Statement

Last Updated November 28, 2017

At ASAPP, Inc. (“we” or “us”), we respect and protect the privacy of our customers and others who use our website, products and services. This privacy statement provides details about how your personal information is collected and used by us. Personal information is any information that identifies you or would enable someone to contact you, which may include your name, email address, phone number and other non-public information that is associated with such information. It does not include aggregate information, anonymous information or any other non-personally identifiable information. This privacy statement applies to the ASAPP website, ASAPP products and services, and any other sites owned or operated by us (the “Sites”). This privacy statement does not cover how our Clients may use the data that we collect on their behalf. For information on how they use data, please contact the applicable Client directly.

ASAPP, Inc. is located at One World Trade Center, 80th Floor, New York, NY 10007.

About the Information We Collect

The only information we collect about you is from information that you voluntarily provide to us. This information may include, for example, a name, mailing address, email address, or phone number.

Should you supply us with any personal information, we will use that information only for the purposes of:

  • • Communicating with you.
  • • Providing you with the information you have requested.
  • • Improving our products and services.
  • • Facilitating your movement through the Sites or your use of our products and services.
  • • Diagnosing problems with our servers or our products and services.
  • • Administering our Sites.

When you visit our website, we may track information to administer the site and analyze its usage. Examples of information we may track include:

  • • Your Internet protocol address. 
  • • The kind of browser or computer you use. 
  • • Number of links you click within the site. 
  • • State or country from which you accessed the site. 
  • • Date and time of your visit. 
  • • Name of your Internet service provider. 
  • • Web page you linked to our site from. 
  • • Pages you viewed on the site. 
  • • We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer, to improve marketing, analytics, and site functionality.

We may aggregate and anonymize information received to produce reports on trends and statistics and we may use third-party services, such as Google Analytics, to collect and analyze such information.

We may also disclose your personal information

  • • as required by law, such as to lawful requests by public authorities, including to meet national security or law enforcement requirements, comply with a subpoena, bankruptcy proceedings, or similar legal process
  • • when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request,
  • • if we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified by a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information,
  • • to any other third party with your prior consent to do so.

Commitment to Security and Privacy

At ASAPP, we take our responsibility to protect the security and privacy of the information we receive extremely seriously. We are continually reviewing our established policies and procedures to ensure that they are appropriate and effective in meeting our commitment to our community, to our Clients and to ourselves.

Our employees and others with duties related to our Sites and services must adhere to the ASAPP Privacy Statement. Our employees receive periodic training about the privacy policies and procedures of ASAPP. We acknowledge that protecting privacy is a key part of our trusted relationship with our Clients.

Information collected via the ASAPP Website

Our Sites may create a file or a “cookie” on the hard drive of your computer to retain information that is used by our Sites. These files are used during your online session to ensure your access to our Sites are authorized and to control certain parameters of your communication session with our Sites. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our Sites, but your ability to use some features or areas of our Sites may be limited.

IP Addresses
An IP (Internet Protocol) address is a number assigned to your computer for accessing the Internet. All computer identification on the Internet is conducted using IP addresses to allow other computers and servers to recognize and communicate with each other. If a visitor requests pages from the ASAPP website, the ASAPP servers enter the visitor’s IP address into a log. ASAPP collects IP addresses to conduct site analysis. We also use IP address information to conduct system administration, manage communication traffic patterns and to investigate threats, mischief, or “attacks” directed at our site or to our visitors.

Please note that ASAPP does not disclose domain name or aggregate information to third parties other than vendors who assist us with our Service and who are under strict confidentiality requirements.

Information collected for our Clients through our Service

The collection and use of information shall be limited to the purpose of providing the service for which the Client has engaged ASAPP. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly.

Data Retention: We will retain data we process on behalf of our Client for as long as needed provide services to our Client. We will retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Access:  As a data processor, we have no direct relationship with the individuals whose data we process. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to our Client (the data controller) which has transferred such data to us for processing. If the Client requests that we remove the data, we will respond to the Client's request within 30 business days. The Client will then provide access to the individual as determined under the applicable local data protection law.

Notice: As an agent processing information under the direction of our Clients, we have no direct relationship with the individuals whose data we process. Our Clients are responsible for providing notice of data processing to individuals, including information concerning (1) the purposes for which personal information is collected and used; (2) a contact person to whom enquiries or complaints may be directed; (3) the types of third parties to whom personal information is disclosed; and (4) the choices and means that individuals are offered for limiting use and disclosure of personal information.

Choice: As an agent processing personal information under the direction of our Clients, we have no direct relationship with the individuals whose data we processes. We may disclose personal data to third parties (such as subcontractors) in the course of processing data. Transfers to third parties are covered by the provisions in this Policy and the service agreements with our Clients. We only processes information in accordance with instructions of our Clients, and only for purposes that are compatible with those for which it was originally collected or subsequently authorized by the individual.

Data Processing Addendum: If you would like to enter into EU standard contractual clauses with us as it relates to our processing of your information we will provide you a DPA for execution.

Notification of Changes

We reserve the right to modify this privacy statement at any time, so please review it frequently. If we decide to change this privacy statement in any material way, we will notify you by means of a notice on