Sensor Tower Privacy Policy

This privacy policy (“Policy”) describes the privacy practices for our website, applications, APIs, and other services accessible via sensortower.com, pathmatics.com, any subdomains of the foregoing domains, or any mobile or desktop applications, including any services, content or functionality offered on or through any of the foregoing and any subdomains and related sites or applications (collectively the “Site”). This Policy is a legal statement that explains how Sensor Tower, Inc. (“Sensor Tower”, “we”, or “us”) may collect information from you, how we may use, maintain, protect, and share your information, and how you can control your information.

This Privacy Policy is incorporated by reference into our Terms of Service (the “Terms”). Please read this Policy and the Terms carefully before you start to use the Site to understand our policies and practices regarding how we treat your information. By accessing or using the Site or by accepting (including by clicking to accept or agree when the option is made available to you) any Terms that incorporate this Policy, you accept and agree to be bound and abide by this Privacy Policy and the Terms. If you do not agree with any terms of this Policy or the Terms, you may not access or use the Site for any purpose.

Contact Information

We are committed to protecting your privacy. If you have any questions, comments, or concerns about your information, this Policy, your privacy, or any of our privacy practices, please contact our Data Protection Officer by email at data-protection@sensortower.com or by mailing correspondence to Data Protection Officer at Sensor Tower, Inc., 2261 Market Street #4331, San Francisco, CA 94114.

Personal Information We Collect

Personal Information (aka, personal data or personally identifiable information)

When you access or use the Site, we may collect the following personal information (also know as personal data or PII) (“Personal Information”):

Profile Data

• First name and/or last name

• E-mail address

• Region (country, state, etc.)

• Title

• Country

• Default device and format types

• Preferred currency

• Application names

• Phone number

• App Platform Accounts for App Platforms

• Keywords and search terms

• Site customizations

• Name and email of other users to invite to the Site

• Electronic notification preferences

Usage Data

We may also collect information on how the Site is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (“IP address”), user agent, browser type, browser version, operating system, the pages of our Site that you visit, search queries you perform, information you may post to the Site, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data, and configuration input provided using the Site’s forms, such as keywords, categories, and search terms.

Customer and Applicant Data

In some cases during prospect and customer engagements, or when interviewing applicants for employment, we may record our meetings. These recordings are used for internal educational purposes only. For such recordings, we use a third-party vendor, gong.io. gong.io’s Privacy Policy can be viewed at https://www.gong.io/privacy-policy/.

App Platform Accounts

Subject to our Terms, if you elect, we may use App Platform Accounts that you connect to the Site to power various features of the Site. If you no longer want any such App Platform Accounts connected to the Site, you can remove the connections from the settings section of your User Account.

Employment-Related Data

We may receive and process employment-related information, such as employment history, resumes, background information, recordings of interviews, and other relevant information to help us to recruit new employees and independent contractors, and to manage our interactions with current employees and independent contractors.

Tracking and Cookies Data

We use cookies to make our site work, help us improve it, and to provide you with information about it. Some essential cookies are required by default and we request your consent to enable others through our Cookie Manager. Our Cookie Manager is available on our Cookie Notice and you can use it at any time to change your cookie preferences.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Site. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site. You can access a list of the cookies that we use via our Cookie Manager (see Cookie Notice).

Web Beacons

Pages of the site and our electronic communications (e.g., e-mails) may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Other Technologies

We may also use device identifiers, local storage, html modifiers, and different types of caching to help us understand the devices and users who access the Site. Those methods include device identifiers that are either hardware-based or software-based, persistent or non-persistent, and which may identify either a device or a software module within a device (such as a web browser).

“Do Not Track” Requests

We adhere to the standards set out in this Policy and do not monitor or respond to Do Not Track browser requests.

Support and Survey Data

At times, you may request assistance with the Site, report an error or bug on the Site, ask questions about your subscription or account, complete a survey, respond to a questionnaire, or otherwise interact with us regarding the Site, and in the process, may provide information to us through forms on the Site or through electronic channels such as email.  We may request additional information related to any requests or submissions to make.

Business Partner Data

We do business with (and aim to do business with) many companies whose employees give us their contact information for communication regarding the Site we render or services we receive from those businesses. We never sell that Personal Information and only use it for purposes of communicating with those businesses. We may use that Personal Information for our own internal purposes to help us improve our business relations processes and practices. We may keep and process that Personal Information after the relationship ends with those businesses when we are required to do so by applicable law or to preserve legal claims that may arise.

Privacy of Children

We are committed to protecting child privacy. The Site is not intended for children and we do not intentionally or knowingly collect information, personal or otherwise, about individuals under the age of 18, much less children under 13 years old. If you are aware of anyone under 18 using the Site, please contact us using the contact information provided above and we will take required steps to delete any such information and/or prevent that individual from accessing the Site.

Sensitive Data

We never intentionally receive or process information regarding your sexual orientation, ethnicity, religious affiliation, refugee status, health, or personal finances.

Anonymized Data

Personal Information does not include anonymized data, which is data that has been rendered anonymous in such a way that you are no longer identifiable (“Anonymized Data”). We may use anonymized data for our own purposes in any manner and without attribution or compensation to any person.

How we collect Personal Information

We collect Personal Information from various sources, such as directly from you when you access or use the Site or automatically as you navigate through the Site. Information collected automatically may include, but is not limited to, Usage Data, tracking and cookies data, and so forth.

How We Use Personal Information

We may use Personal Information for the following reasons:

• To provide and maintain the Site;

• To personalize the Site;

• To provide customer support;

• To detect, prevent, and address technical issues with the Site; 

• To monitor Site usage;

• To secure the Site;

• To conduct research and development including the development of new features, tools, and functionality;

• To notify you regarding changes to our Site including features, tools, and functionality provided by the Site;

• To notify you about our current or new offerings; and

• To contact you for market research purposes including completing surveys and questionnaires.

Use for new purposes. We may use your Personal Information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your Personal Information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Legal Basis for Collecting Personal Information

If you are from the European Economic Area (“EEA”) or the United Kingdom (“UK”), our legal basis under the General Data Protection Regulation for collecting and using the Personal Information described in this Policy depends on the Personal Information we collect and the specific context in which we collect it. We may process your Personal Information because:

• We need to perform a contract with you;

• You have given us permission to do so;

• The processing is in our legitimate interests and it's not overridden by your rights;

• For payment processing purposes; and/or

• To comply with the law.

How We Share Personal Information

We may share Personal Information with third parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection. Such sharing may include:

• Affiliates. We may share Personal Information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

• Service providers. We may share Personal Information with third party companies and individuals that provide services on our behalf or help us operate the Site and our business (such as customer support, hosting, analytics, email delivery, marketing, and database management services) (see Service Providers below). For your reference, a list of our sub processors and nature of processing can be found at trust.sensortower.com.

• Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.

• Partners. We may sometimes share Personal Information with partners or enable partners to collect information directly via our Site.

• Professional advisors. We may disclose Personal Information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

• Compliance, fraud prevention and safety. We may share Personal Information for the compliance, fraud prevention and safety purposes described above.

• Business transfers. We may disclose Personal Information in the context of actual or prospective business transactions (e.g., investments, financing, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares). For example, we may need to share certain Personal Information with prospective counterparties and their advisers. We may also disclose some or all of your Personal Information to an acquirer, successor or assignee of Sensor Tower as part of any business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization, sale of assets, or similar transaction, and/or in the event of bankruptcy, dissolution, or receivership in which Personal Information is transferred to one or more third parties as one of our business assets.

• Legal Disclosure. We may disclose Personal Information if required to do so by law or in the good faith belief that such action is necessary to conform to applicable law, comply with a judicial proceeding, court order or legal process served on us, protect and defend our rights or property, or investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of our Terms.

• Consent. We may share your Personal Information for any other purpose disclosed to you and with your consent.

Without limiting the foregoing, in our sole discretion, we may share Anonymized Data or de-identified information about you with third parties or affiliates for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your Personal Information, please see the Your data protection rights and choices section below.

Your Data Protection Rights and Choices

In this section, we describe the rights and choices available to all users. Users located in the EEA, UK, Switzerland, and various US states can find additional information about their rights below in the section entitled accordingly. 

Your Rights Under the GDPR

If you are a resident of the EEA, UK, or Switzerland, you may have certain data protection rights including:

• The right to access, update or to delete the Personal Information we have about you;

• The right to have your Personal Information rectified if that information is inaccurate or incomplete;

• The right to object to our processing of your Personal Information;

• The right to request that we restrict the processing of your Personal Information;

• The right to be provided with a copy of your Personal Information in a structured, machine-readable and commonly used format; and

• The right to withdraw your consent at any time where we relied on your consent to process your Personal Information.

How to exercise your privacy rights

Contact our Data Protection Officer using the contact information provided above to exercise any of your privacy rights. We commit to grant them within 30 days after receipt or less.

Article 27 Representative

If you reside in Europe or the UK, you can also contact Osano, which has been appointed as our representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. If you are in the European Economic Area, Osano can be contacted in addition to our Data Protection Officer, only on matters related to the processing of personal data. To make such an inquiry, please contact Osano by mail using the contact information below: 

UK Representative

Osano UK Compliance LTD

ATTN: 8QL4

42-46 Fountain Street

Belfast

Antrim

BT1 - 5EF

EU Representative

Osano International Compliance Services Limited

ATTN: 8QL4

3 Dublin Landings

North Wall Quay

Dublin 1

D01C4E0

Other Items

Notification requirements. We commit to notify you, when it is needed under the law, within a reasonable period of time and your data protection authority within the timeframe specified in applicable law about data breaches related to your Personal Information.

Data Protection Authorities. Subject to applicable laws, you may have the right to lodge a complaint with your local data protection authority about any of our activities that you deem are not compliant with applicable law.

Cross-Border Data Transfers. If we transfer your Personal Information from the EEA or UK to another country that is not deemed by the European Commission and/or UK Government, as applicable, to provide an adequate level of protection to Personal Information, that transfer will be performed subject to appropriate safeguards and otherwise in accordance with applicable European data protection legislation. For example, we may use specific appropriate safeguards, which are designed to give Personal Information effectively the same protection it has in Europe – such as standard-form contracts approved by relevant authorities for this purpose. Please contact us for further information about any such transfers or the specific safeguards applied.

Your Rights Under the California Consumer Privacy Act (“CCPA”)

If you are a California resident, then Under the California Consumer Privacy Act (“CCPA’’), you have certain rights regarding the Personal Information that we may have collected about you. These rights may include the following:

• You can request the following information about how we have collected and used your Personal Information during the past 12 months:

  • The categories of Personal Information that we have collected;

  • The categories of sources from which we collected Personal Information;

  • The business or commercial purpose for collecting, selling and/or sharing Personal Information;

  • The categories of third parties with whom we disclose Personal Information;

  • The categories of Personal Information that we sold, disclosed, or shared for a business purpose, and

  • The categories of third parties to whom the Personal Information was sold, shared or disclosed for a business purpose;

• You can request a copy of the Personal Information that we have collected about you during the past 12 months;

• You can ask us to delete the Personal Information that we have collected from you;

• You can ask us to correct inaccurate Personal Information that we have collected about you;

• You can request to opt-out of disclosures of your Personal Information that constitute “selling” or “sharing” of your Personal Information as defined in the CCPA; and

• You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.

Please note that your rights to have Personal Information deleted are subject to several exceptions, specifically the Personal Information that is necessary for us to:

• Complete your transaction;

• Provide you a good or service;

• Perform a contract between us and you;

• Protect your security and prosecute those responsible for breaching it;

• Fix our system in the case of a bug;

• Protect the free speech rights of you or other users;

• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code §1546 et seq.);

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;

• Comply with a legal obligation; or

• Make other internal and lawful uses of the information that are compatible with the context in which you provided it.

You may read more about your California privacy rights here. 

How to Exercise Your Privacy Rights

Contact our Data Protection Officer using the contact information in the Contact information section above to exercise any of your privacy rights. We commit to respond to your request within 30 days after receipt or less. We may require you to prove your identity in some cases as noted in further detail below. This is made to ensure that no rights of third parties are violated by your request.

Please keep in mind that in the case of a vague request we may engage in a dialogue so as to better understand the motivation and content of the request. We reserve the right to reject requests that are unduly burdensome or repetitive in nature, or if there are legal obligations to maintain the data due to a dispute, compliance, audit, or other investigation.

Verification of Identity

To verify your identity, we may require receipt of an email from an account that matches the email we have on record for you (if one exists), authentication into an online account with us (if you have one), information that we match against information we maintain about you, government identification, a declaration under penalty of perjury or other information, where permitted by law. Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide your agent with written and signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity, and provide us with written confirmation that you have given the authorized agent permission to submit the request.

Categories of Personal Information We Collect

As summarized in detail in the Personal Information we collect section above, depending on our relationship, we may collect:

• Personal identifiers;

• Employment information;

• Commercial information; and

• Internet or other electronic network activity information.

The basis for the collection of Personal Information and the manner in which Personal Information is used is outlined elsewhere in this document. 

Sharing or Sale of Your Personal Information

We may share your Personal Information under the circumstances outlined in the How we share Personal Information section above.

Notice of Right to Opt-Out of the “Selling” or “Sharing” of Your Personal Information

Like many companies, we use services that help deliver interest-based ads to you as described in the Marketing and Advertising section above. Our use of some of these services may be classified under California law as a “selling” or “sharing” your Personal Information (including your business and personal contact information, device data, and online activity data described above in “Personal information we collect” section above) with the advertising partners that provide the services. You can submit requests to opt-out of this “selling” or “sharing” as noted above. We have no actual knowledge that we have sold or shared the Personal Information of any California residents under the age of 18.

Anonymized Data

Anonymized Data, which cannot be re-identified and does not identify you or any individual person, is exempted under the CCPA (e.g., see Section 1798.145. Exemptions) and may be shared with third parties or provided for sale as summarized in the Anonymized Data section above.

Shine the Light

California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about businesses’ practices related to disclosing Personal Information to third parties for the third parties’ direct marketing purposes. Alternatively, such businesses may have in place a policy not to disclose Personal Information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We do not participate in the sharing of your Personal Information with third parties for the third parties’ direct marketing purposes, so there is no need to opt-out.

Your Rights in Various Other Jurisdictions

Various other states, including but not limited to, Colorado, Connecticut, Virginia, and Utah, have passed laws providing their state residents rights that are the same or similar to those afforded under the CCPA and the GDPR. These rights, which we honor in the same fashion as outlined above, include without limitation rights to:

• Confirm whether we process their Personal Information.

• Access and delete certain Personal Information.

• Data portability.

• Opt-out of Personal Information processing for targeted advertising and sales.

Some states also provide their state residents with rights to:

• Correct inaccuracies in their Personal Information, taking into account the information's nature processing purpose.

• Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

Outside of the US, if you are a resident of another country, state, or province with applicable data privacy laws and regulations that afford you with privacy rights similar to those afforded by the GDPR, CCPA, or other similar laws or regulations, we will honor any requests from you to exercise those privacy rights in accordance with those data privacy laws and regulations to the extent possible.

Communication Opt-out

You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us using the information in the Contact information  section above. Note that you may continue to receive service-related and other non-marketing emails.

Declining to provide information

We need to collect certain Personal Information to provide the Site. If you do not provide the Personal Information we identify as required or mandatory, we may not be able to provide the Site.

Data Retention

We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We store some information indefinitely for operational purposes, such as technical support and abuse prevention. Other data such as web server logs or store sales reports are only kept as long as space is available for them. Please note that if you request that your Personal Information be removed from our databases, it may not be possible to completely delete all of your Personal Information due to technological and legal constraints.

The retention period is determined by various criteria such as the type of user, the services to which you subscribe, and the nature of our relationship. The retention period can be lengthened or shortened based on the cancellation or re-enrollment in our Site. The retention period can also be modified based on internal changes in auditing requirements and/or mandatory retention periods provided by law and statute of limitations.

Transfer of Data

Your information, including Personal Information, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other Personal Information.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Service Providers

In our continuing efforts to provide our Site in a manner that is convenient and helpful to a growing number of customers, we use the services of service providers (“Service Providers”) to help us host and secure the Site, perform Site-related services, analyze how the Site is used, and manage our business. These services, which include but are not limited to companies that provide cloud services, infrastructure, analytics services, and software to help us host and maintain the Site, and manage our business and customer relationships, may process Personal Information.  We take commercially reasonable steps to ensure that these Service Providers are secure and, do not sell or disclose the Personal Information to other parties, or use Personal Information for any purposes other than the services they are providing to us.

A non-exhaustive list of Service Providers we use that process Personal Information is available on our Trust Center at trust.sensortower.com.  

Google Analytics

Please note that we use Google Analytics to assess how users are interacting with the site. The privacy practices of Google Analytics are available at www.google.com/policies/privacy/partners/ and you may opt out of the use of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout.

Slack

Some customers elect to communicate with us using Slack through Slack channels and direct Slack messages (DMs).  By communicating with Sensor Tower via Slack in such a way, you acknowledge that Slack will share your Personal Information with Sensor Tower including your name, contact information, and any other Personal Information you elect to share in the messages that are exchanged. We are not responsible for Slack’s data practices and urge you to review Slack’s privacy policy, which can be viewed at 

https://slack.com/trust/privacy/privacy-policy, prior to using Slack’s services in this way. Should you desire to exercise your privacy rights with respect to your Personal Information, we urge you to:

• Contact Slack’s data protection officer based on the information provided by Slack in its privacy policy and follow the outlined procedure; and/or

• Submit a privacy right request based on the process outlined in this policy and, we will honor the request directly to the extent with which we are able within Sensor Tower systems and/or may submit a third party request to Slack to honor the request.

Recruiting Providers

We use the services of third parties to help us to recruit new employees and independent contractors and to manage our interactions with current employees and independent contractors. We do our best to contractually ensure that these third-party service providers comply with the policies we have adopted. However, we can’t guarantee their compliance in every case. We only use employment Personal Information for the direct purpose of the employment or independent contractor relationship, and we cease using it as soon as that relationship ends. However, we may keep and process that Personal Information after the relationship ends when we are required to do so by applicable law or to preserve legal claims that may arise.

Security

The security of your Personal Information is important to us. We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us as outlined on our Trust Center available at trust.sensortower.com. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you. Unfortunately, as the Internet is not 100% secure, and we cannot ensure or warrant the security of any Personal Information transmitted via the Internet.

Third-Party Links, Sites and Services

You may be able to access third-party websites and other tools, services, or products via our Site, a link, or via our other tools. The privacy policies of these third parties are not under our control and may differ from ours. The use of any Personal Information that you may provide to any third parties will be governed by the privacy policy of such third party or by your independent agreement with such third party, as the case may be. If you have any doubts about the privacy of the information you are providing to a third party, we recommend that you contact that third party directly for more information or to review its privacy policy.

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any offering, site or other products and services used in connection with the Site. The inclusion of functionality or a link does not imply endorsement of the linked site or service by us or by our affiliates.

Changes to this Privacy Policy

We reserve the right to change this Privacy Policy at any time. Any change to this Privacy Policy will become effective on the date it is posted. We recommend that you retain a copy of this Privacy Policy for your reference and revisit this policy from time to time to ensure you are aware of any changes. Your continued use of the Site signifies your acceptance of any changes.

Date of last update

This policy was last updated on January 5, 2024.