Effective Date: January 3, 2019
Table of Contents:
- About Us.
- Information We Collect.
- How We Use the Information We Collect.
- Maximum Information Retention Period.
- How We Share Your Information.
- International Transfers.
- Contact Us.
InstallCore (www.installcore.com) operates a platform that allows website owners and software developers (“Publisher Partners”) to offer you additional software suggestions when you browse or download software from their website.
We collect information in either of 2 ways:
- Directly - From your device through our platform integrated by Publisher Partners.
- Indirectly - Depending on our agreement with our advertisers, we receive information from such advertisers if you performed an action on their software or website that will entitle us to a payment in connection with such action.
We collect these kinds of information for InstallCore’s own purposes, as a data controller under data protection law where relevant.
- Information collected directly from you through our platform -
Identifiers: We identify your device based on a unique user ID we generate, and your device’s GUID (which is a unique identifier associated with your device). We also collect additional identifiers from your device, such as your IP address and MAC address, for the purpose of detecting and preventing fraud and other interactions initiated by automated means. We also use your IP address to infer the country and city in which you are located.
General technical information about your device: hard drive space, size of system memory, CPU, video hardware, registry keys, list of running processes, browser types, browser extensions, installation date, changes made in your system, time zone, operating system, whether you installed the Publisher Partner’s software with administrative privileges, your default search providers, browser language, operating system language, whether the system is 32bit or 64bit, the name of the Publisher Partner’s software and name of offers installed by you through our platform.
Interaction with our platform: An indication of your interactions with our platform.
- Information received from our advertisers through a pixel implemented on their website or software - We receive from advertisers through a pixel implemented on their website or software an indication that you performed an action that would entitle us for a payment from the advertiser. We will also receive together with such indication a unique user ID generated by us.
As stated above, our platform allows Publisher Partners to offer you with additional software suggestions when you browse or download software from their website. Below is a general description of how we use your information across our services:
- Downloading and installing Publisher Partner’s and Advertiser’s software - we use your information to technically enable the downloading and installation of software.
- Analytics, reporting and billing - We use your information to analyze your interactions with our platform, generate reports for our Publisher Partners and advertisers and bill advertisers.
- Attribution - We use your information to ensure that if you downloaded offers through our platform, we will receive payment for our services from advertisers.
- Internal Operations - We use your information for internal operations, such as debugging, support, security, and improving our services.
- Frequency capping - We use your information to limit the number of times you view a specific offer on our platform.
- Fraud detection and prevention - We use your information for detecting and preventing fraud.
- Optimization and personalization - We use your information for optimizing offers and to ensure you receive offers that are compatible with and relevant to your device features and settings.
- Compliance with legal obligations - We may use your information to comply with applicable legal obligations.
The GDPR Angle:
- We act as a controller and process personal data on the basis of our legitimate interest – When we process your personal data for the purposes mentioned above, we process such data on the basis of our legitimate interest. Accordingly, we will process your personal data for enabling the download and installations of software requested by you, to analyze your interactions with our platform so we can improve the service, to ensure we receive payment for our services, to operate our platform in a secure way and to provide you with a great user experience, to ensure you do not receive an offer too many times, and to ensure that an offer is compatible with your device and its settings and features.
- Further processing of information received from advertisers – When we process information received from advertisers, we may further process such information for optimization of our network based on our legitimate interest.
- Legal necessity – We may process your information for compliance with applicable legal obligations.
- Data subject rights – Please note that you have the right to request from us access to and rectification or erasure of your personal data we process as controllers, or to restrict or to object to the processing of your personal data in accordance with the provisions of the GDPR. In order to submit a request for accessing and/or deleting your information, you can use the tool we developed for such purpose by downloading it through the following link: Mac and Windows. To submit a request for exercising your other rights, please send an email with your request to the following address: firstname.lastname@example.org. Please note that we will process your request subject to verification of your identity.
- Complaint to supervisory authority – You also have the right to file a complaint with the relevant supervisory authority (e.g. of your country or domicile) where we have not addressed your concerns.
We will retain your information for a period of up to 3 years from the date such information is first stored in our systems, except for one copy we will store for the purpose of compliance with legal obligations and establishing, defending, and exercise legal claims.
- Our corporate affiliates - from which we receive services, such as IT, security, storage, delivery of advertising campaigns, and other internal operations.
- Service providers - We share your information with our service providers for the purpose of receiving services such as security, fraud detection and prevention, reporting, and storage.
- Publishers and Advertisers - We share your information with advertisers for reporting and measurement purposes.
The GDPR Angle:
We do not collect or otherwise process personal data from individuals in the European Economic Area, the United Kingdom, and Switzerland whom we know to be under 16 years of age, except to comply with the law or to support our legitimate interests or the legitimate interests of our app developers as described above.
We store information that we collect from your device on our Amazon Web Services servers in the United States. Accordingly, please note that if you do not live in the United States, we will transfer your information to and store it in, the United States.
The GDPR Angle:
If you are located in the European Economic Area, the United Kingdom, or Switzerland, we will transfer your information to the United States based on the Standard Contractual Clauses. If you wish to receive a copy of these clauses, please contact us through the below contact details.
121 Menachem Begin Rd., Tel Aviv, Israel
Attn: Data Protection Officer