Effective Date of Current Policy: February 14, 2019
The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Audm and the requirements of applicable law. Some of the ways that Audm may collect Personal Information include:
· You may provide Personal Information directly to Audm through interacting with the Services, participating in surveys, during events such as sweepstakes, and when you request Services or information.
· As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.
We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
Audm collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, guests, and Employees (collectively “Individuals”).
· Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an Account with Audm, responding to surveys, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:
o Communications with Us. We may collect Personal Information from you such as email address and name when you choose to request information about our Services, register for communications that we may offer from time to time, request to receive customer or technical support, or otherwise communicate with us.
o Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, IMEI, other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services.
· Information from Other Sources. We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you. For example, if you access our Services through a Third-Party application, such as an App Store or social networking service (“SNS”), we may collect information about you from that Third-Party application that you have made public via your privacy settings. Information we collect through App Stores or SNS accounts may include your name, email, and other identifying information. This supplemental information allows us to more easily register you for and provide you the Services.
We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:
· To Provide Products, Services, or Information Requested. Audm may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
o Generally manage Individual information and Accounts
o Respond to questions, comments, and other requests
o Provide access to certain areas, functionalities, and features of the Services
o Contact you to answer requests for customer support or technical support
· Administrative Purposes. Audm may use Personal Information about you for its administrative purposes, including to:
o Measure interest in Audm’s Services;
o Develop new products and Services;
o Ensure internal quality control;
o Verify Individual identity;
o Communicate about Individual Accounts and activities on Audm’s Services and systems, and, in Audm’s discretion, changes to any Audm policy;
o Send email to the email address you provide to us to verify your Account and for informational and operational purposes, such as Account management, customer service, or system maintenance;
o Process payment for products or services purchased;
o Process applications and transactions;
o Prevent potentially prohibited or illegal activities;
o Enforce our Terms.
· Marketing Audm Products and Services. Audm may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Audm may provide you with these materials by email and as permitted by applicable law. Such uses include:
o To tailor content, advertisements, and offers;
o To notify you about offers, products, and services that may be of interest to you;
o To provide Services to you and our sponsors;
o For other purposes disclosed at the time that Individuals provide Personal Information; or
o Otherwise with your consent.
You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described in Section 6 below.
· Research and Development. Audm may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our Services or develop new products and services. We may share anonymous Individual and aggregate data for research and analysis purposes.
· Email Marketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails from us with information on Audm’s products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 6 below.
· Anonymous and Aggregated Information Use. Audm may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Audm’s Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Audm may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Audm and with Third Parties for our or their purposes in a form designed to prevent anyone from identifying you.
· Sharing Content with Friends or Colleagues. Audm may allow you to provide information about your friends through an in-App referral link. Email addresses that you may provide for a friend or colleague will either be embedded within your outgoing mail application for you to send yourself or will used solely to send the email link you have authorized and for no other purpose.
· Other Uses. Audm may use Personal Information for which we have a legitimate interest, such as individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
· Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
· Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on a webpage that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
· Mixpanel. We use a service provided by Mixpanel, Inc. (“Mixpanel”) to provide us with analytics data regarding users’ interactions with our Site and Services by transmitting certain Log Data to Mixpanel. You may opt-out of Mixpanel’s automatic retention of data that is collected while using the Services by visiting . To track opt-outs, Mixpanel uses a persistent opt-out cookie placed on your device. Please note that if you get a new computer, install a new browser, erase or otherwise alter the browser’s cookie file (including upgrading certain browsers), you may delete the Mixpanel opt-out cookie.
· Our uses of such Technologies fall into the following general categories:
· Operationally Necessary. We may use Technologies that are necessary to the operation of our Services. This includes Technologies that allow you access to our Services; that are required to identify irregular behavior within our Services, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved searches, or similar functions;
· Performance Related. We may use Technologies to assess the performance of our websites, applications, services, and tools, including as part of our analytic practices to help us understand how users interact with our Services, determine whether you have viewed an item or link, or to improve our Services;
· Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign in or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of our Services;
· Advertising or Targeting Related. We may use first-party cookies and other Technologies to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using Technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt-out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits, or as described above in with respect to certain analytics service providers.
The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and Audm does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
When you make purchases through the Services, we process your payments through a Third-Party application, including App Stores. The Third-Party application may collect certain financial information from you to process a payment on behalf of Audm, including your name, email address, address and other billing information.
Audm collects Personal Information from current, prospective, and former Employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy. We may also collect Sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave; information about national origin or immigration status; and optional demographic information such as race, which helps us achieve our diversity goals.
We acquire, hold, use and Process Human Resources Data for a variety of business purposes including:
· Workflow management, including assigning, managing and administering projects;
· Human Resources administration and communication;
· Payroll and the provision of benefits;
· Compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs;
· Job grading activities;
· Performance and employee development management;
· Organizational development and succession planning;
· Benefits and personnel administration;
· Absence management;
· Helpdesk and IT support services;
· Regulatory compliance;
· Internal and/or external or governmental compliance investigations;
· Internal or external audits;
· Litigation evaluation, prosecution, and defense;
· Diversity and inclusion initiatives;
· Restructuring and relocation;
· Emergency contacts and services;
· Employee safety;
· Compliance with statutory requirements;
· Processing of Employee expenses and travel charges; and
· Acquisitions, divestitures, and integrations.
· We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site. Audm has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
· Third Party Marketing. We may share de-identified information we have collected with Third-Party advertising partners. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt-out of such sharing at no cost by following the instructions in Section 6 below.
· Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other Account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Audm policies or contracts; (v) to collect amounts owed to Audm; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
All Personal Information collected via or by Audm may be stored anywhere in the world, including but not limited to, in Uganda, India, the United States, on our servers, or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Audm, you consent to the storage of your Personal Information in these locations.
You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to Audm’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt-out to further Processing by contacting . Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
Audm may occasionally send you push notifications through our mobile applications with notices that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. Audm may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
With regard to Personal Information that Audm receives in connection with the employment relationship, Audm will use such Personal Information only for employment-related purposes as more fully described above. If Audm intends to use this Personal Information for any other purpose, Audm will notify the Individual and provide an opportunity to opt-out of such uses.
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at , or and .
Although Audm makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Audm is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Audm determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Audm will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site, via the functionality of the Services, or by sending an e-mail to you. You may have a legal right to receive this notice in writing.
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to Uganda, India, the United States, and other jurisdictions as we may have employees, and to the Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.
The Services are not directed to children under 13 (and in certain jurisdictions under the age of 16) years of age, and Audm does not knowingly collect Personally Identifiable Information from children under 13 (and in certain jurisdictions under the age of 16) years of age. If you are under the age of 18 or the age of majority in your jurisdiction, you must have your parent’s permission to access the Services and the games. Audm urges parents to instruct their children never to give out their real names, addresses, or phone numbers, without parental permission, when online. If you learn that your child has provided us with Personal Information without your consent, you may alert us at . If we learn that we have collected any Personal Information from children under 13 (and in certain jurisdictions under the age of 16), we will promptly take steps to delete such information and terminate the child’s Account.
· New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt-out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, Audm will endeavor to comply with the law or contract.
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Audm does not share Personal Information with Third Parties for their own marketing purposes.
The following capitalized terms shall have the meanings herein as set forth below.
· “Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, Audm or to which Audm discloses Personal Information for use on its behalf.
· “Employee” refers to any current, temporary, permanent, prospective or former employee, director, contractor, worker, or retiree of Audm or its subsidiaries worldwide.
· “Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).
· “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
· “Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the Individual’s sex life; or (8) information relating to the commission of a criminal offense.
· “Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Audm or Audm’s Agents.
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