Privacy Policy

Last Updated: August 07, 2026

Previous version: July 21, 2026


We’re not trying to hide it: AppFollow (defined below) collects and stores personal information needed to provide our Service and Consultancy Service. We are committed to being transparent about it and keeping your personal information safe, so this Privacy Policy defines our policies and procedures regarding the collection, use, protection and disclosure of Personal Data in connection with our Service, Consultancy Service and the Website and describes the choices available to you regarding Personal Data. This Privacy Policy also explains what rights you have and how to update and correct your personal information.

Where AppFollow processes Customer’s Personal Data on behalf of a Customer, that processing is governed by our Data Processing Agreement (“DPA”), available here. The DPA is incorporated into and forms an integral part of our Terms and Conditions and applies automatically to that processing, without any need for a separate signature, a countersigned copy is available on request.

Scope of this Privacy Policy. This Privacy Policy is our controller-side notice. It describes in full the processing where AppFollow itself decides the purposes and means – namely data about the Customer’s representatives and contact persons, billing contact data, Users of our Service and Consultancy Service, and visitors of our Website. Where AppFollow instead acts as a processor on a Customer’s behalf (Section 2 below), this Privacy Policy gives an overview only: the operative terms for that processing – including the list of subprocessors, the technical and organisational measures, personal data breach notification, and audit and assistance rights – are set out in the DPA rather than here.

We turn to the definitions given by the General Data Protection Regulation (2016/679) when it comes to meanings of ‘personal data’, ‘data subject’, ‘processing’, ‘controller’ and ‘processor’.

We collect or store information about: i) the Customers and their representatives and contact persons, ii) the Users of the Service and Consultancy Service, iii) reviewers who have published reviews in publicly available Application Stores, and iv) visitors of AppFollow website www.appfollow.io (‘Website’).

This Privacy Policy forms an integral part of and is incorporated into our Terms and Conditions, so please, make yourself a nice cuppa and review this Privacy Policy carefully before using the Website or subscribing to or using our Services. 

Stay sharp, though — this Privacy Policy is an information notice, not a consent form. We do not ask you to agree to it, and using the Website or the Service is not treated as your consent to anything described in it. Where we do rely on your consent, we ask for it separately and specifically. Cookies that are strictly necessary for the Website and the Service to work are used without consent, as permitted by Article 5(3) of the ePrivacy Directive (2002/58/EC) as implemented in Finland by the Act on Electronic Communications Services (917/2014). Every other cookie is used only after you have given consent through an explicit opt-in in the cookie banner on our Website, and you can withdraw that consent at any time. See the Cookie Policy section below. You can still enjoy that cuppa, though.

Sometimes things change and thus this Privacy Statement may be updated from time to time. An up-to-date version will be available on our Website. In case such a change is required, which would reduce your rights, AppFollow will provide a prior notice thereof.

Any capitalized terms in this Privacy Policy shall have the same meaning as in our Terms and Conditions, unless otherwise specified. To keep things clearer, let’s go ahead and make a few further specifications right now: in this Privacy Policy

(i) ‘AppFollow’ means the AppFollow entity with which you have an agreement. This is either AppFollow.fi Oy, a limited liability company incorporated under the laws of Finland, having its principal place of business at Bulevardi 21, 00180 Helsinki, or AppFollow, Inc., a Delaware corporation having its principal place of business at 470 Ramona Street, Palo Alto 94301, California. If you are a visitor to our Website and have not entered into an agreement with either AppFollow entity, AppFollow.fi Oy is the controller of your Personal Data for the purposes described in this Privacy Policy and is your primary point of contact for privacy-related matters.

(ii) ‘AppFollow Personal Data’ refers to personal data collected and processed by AppFollow of the Customer’s representatives and contact persons, Users of our Service or Consultancy Service, as well as visitors of our Website – here AppFollow is the controller;

(iii) ‘Customer’s Personal Data’ refers to personal data processed by AppFollow relating to reviewers and app publishers as well as to any social media or email accounts linked to the Service – here AppFollow is the processor while the Customer is the controller; and

(iv) ‘Personal Data’ refers jointly to AppFollow Personal Data and Customer’s Personal Data.

Okay, let’s get moving.

Personal Data and Sources of Data

The Personal Data collected and/or processed by AppFollow can be divided into two different sets: AppFollow Personal Data, for which AppFollow is the controller, and Customer’s Personal Data, for which AppFollow is the processor.

1. AppFollow Personal Data

We collect the data we need to be able to enter into an agreement with Customers, to be able to fulfil our obligations regarding our Service and Consultancy Service and to be able to contact each Customer if needed. We further collect this information for marketing, statistics and improvements of our Service and Consultancy Service. In relation to the information defined in this Section 1, we are the data controller.

As the controller, our processing is limited to the following: the contact details of the Customer’s representatives and contact persons, including the name and email address of the person to whom an invoice is to be sent, details of the subscription and of the payments made to us, and usage, technical and cookie data relating to the Website and the Service. We do not apply artificial intelligence or machine learning to any of this data. The AI functionality of our Service operates only on Customer’s Personal Data, where we act as a processor – see Section 2 below.

When breaking it down, this means we gather the following information:

👩‍💻 Contact data - name of each representative and/or contact person of the Customer (company) as well as representatives’ email address, phone number and role/title. In case the Customer signs up for the Account by using a social media account, we will get this information from the social media account. In case our Customer is not a company but a natural person, this information is collected about said natural person.

💻 Account data – meaning details of your subscription (type, length, fee), which may be personal data only if the Customer is an individual, and any feedback potentially given to us by the User.

📊 Usage data – meaning information and statistics of how and how often the User uses our Service or Consultancy Service, how many Apps the User is following, geographical location (country), IP address for trouble-shooting purposes and details about the size of the screen and browser window.

🔧 Technical data – meaning information regarding the number of visitors to our Website divided geographically by countries, which is done for statistics and marketing purposes. In detail, this means the IP address, browser type and version, location (country), operating system and platform, and language.

💶 Transactional data – meaning data regarding the amounts, dates and methods of payments (credit card or invoice) the Customer has made to AppFollow. This may be Personal Data only if the Customer in question is an individual.

📱 Publicly available publisher data – where an app publisher is a natural person, we may process the publisher’s name as displayed in an Application Store for the limited controller-side purpose described in Appendix 1.

How do we get this data, you may ask. Well, Contact data is given to us by Customers and Users. Account data, Usage data, Technical data and Transactional data is collected by us via your use of our Service or Consultancy Service, our Website, and also via cookies (more on these later on – hang in there).

Rest assured, we do not collect any of the following:

🕵️ Personal information – meaning date of birth, marital status or gender.

🏳️‍🌈 Sensitive personal information – meaning personal data regarding racial or ethnic origin, political opinions, religious or philosophical beliefs, genetics, health, sexual orientation, and so forth.

💳 Financial data – meaning the Customer’s or the User’s personal bank account or card details. We don’t process the payments for our Service or Consultancy Service ourselves, so we do not collect any financial data except for when a payment was made (time), in what amount (sum) and with what method (credit card or invoice). Instead, the Customer is requested by our payment provider to provide certain personal data in order to make payments for our Service or Consultancy Service. Such payments are carried out between the payment provider and the Customer, meaning that for such data AppFollow is neither the controller nor the processor. In practice, payments reach us either through our payment provider’s acquiring solution or against an invoice we issue, in the latter case all we hold is the billing contact details and the invoice data. We never hold card numbers or bank account details.

We don’t collect the aforementioned information because we simply don’t need it for anything.

2. Customer’s Personal Data

We collect the data we need to be able to provide our Service and Consultancy Service. This data is collected from publicly available Application Stores regarding Apps chosen by the Customer. In relation to information defined in this Section 2, we are the data processor and the Customer is the data controller.

When breaking it down, this means we process the following information:

👋 Contact data - name or nickname of the reviewer as entered by the reviewer when writing and publishing a review.

🌍 Usage data – meaning geographical location (country) of where each review was published, and the language of the review, to be able to provide our Service and Consultancy Service. We also collect the reviewer’s OS version, and device model in Google Play, in case the reviewer has made the necessary integrations. This is done to understand to which application version the review is related to.

📄 Content data – we process and analyze the reviews published in Application Stores and thus we may process any and all information included in the titles, body texts or other textual parts of reviews, as published by each reviewer and as chosen to be analyzed by our Customers.

💰Transactional data – we process and analyze the number and sums of payments and/or purchases made within our Customer’s application, subject to the Customer making the necessary integrations. This is not Personal Data, however, as this data cannot be traced back to any individual data subject (we do not, for example, have access to any information regarding payment methods or credit card numbers).

This data we gather from publicly available Application Stores. Each reviewer has either submitted this information to an Application Store themselves, or this information has been collected by the Application Store in question. The exception is the Transactional data, which we collect through the integrations possibly made by our Customer.

Regarding the Customer’s Personal Data, the Customer as data controller is responsible for ensuring that such Personal Data is collected for legitimate purposes. The Customer is also responsible for providing information, if applicable, to data subjects about data collection/processing and the rights of data subjects.

AI functionality – and where it does and does not apply. Our Service includes features that use artificial intelligence, for example semantic analysis and tagging of reviews, summaries of sets of reviews, and suggested or automated replies. These features operate exclusively on Customer’s Personal Data as described in this Section 2, where AppFollow acts as a processor on the Customer’s instructions and under the DPA. They are not applied to the AppFollow Personal Data described in Section 1, where we are the controller: that data is not put through any AI or machine-learning processing. Content produced by these features is labelled within the Service with AI metadata, so that it can be identified as AI-generated, and the Customer keeps the ability to review, edit or reject that content before it is published. We make human review of AI-generated replies available and we recommend it as the default way of working, so that the Customer can assure the quality and appropriateness of what is published, it is the Customer who decides whether to enable automated publication. The AI subprocessors we engage, the data locations involved and the applicable transfer safeguards are set out in the DPA.

We would further like to note that the Customer’s Personal Data is only processed by AppFollow subject to a Data Processing Agreement between the Customer and AppFollow, and according to this Privacy Policy. The processing is always carried out on behalf of the Customer, at the Customer’s request and according to the Customer’s instructions.

It is very important that you as a Customer and/or User keep your Personal Data up-to-date and accurate, as we need it to be able to provide you with our Service and Consultancy Service. Kindly be in touch, should there be any changes while you’re our Customer and/or User.

How We Use Your Data

We use your data for the following purposes:

👷 Providing our Service and Consultancy Service: we use Personal Data to both set up the designated User(s) with our Service or Consultancy Service, meaning enabling the Users to use such, and to be able to provide our Service and Consultancy Service, including the functionalities provided by them, to the Customers and Users.

✍️ Handling customer agreements: when you have an Account with us and/or are using either our Service, Consultancy Service or both, it means we have an agreement with you and vice versa. We’re happy about that! We use AppFollow Personal Data for fulfilling our contractual obligations as well as handling and managing our Customer agreements, including getting in touch with you, if needed, regarding the specifics of your subscription, and any potential issues. We may also contact you for marketing purposes, but you can opt out whenever (more on this later).

🛠️ Improving our Service and Consultancy Service: we use AppFollow Personal Data, namely feedback potentially provided by Customers and Users, as well as any details and recorded logs of issues and trouble-shooting activities with our Service and Consultancy Service, to fix said issues, potential bugs, and to overall develop and make our Service and Consultancy Service better. IP addresses are also collected for, and only for, this purpose.

📈 Statistics and analytics for marketing and developing purposes: we use geographical data (countries), anonymized statistics of the number of Customers, Users, visitors to the Website, and similar metrics to see how we could improve our Service and Consultancy Service, and for marketing purposes. All of this is AppFollow Personal Data.

📇 Compliance with applicable laws: we also use Personal Data to comply with requirements of the GDPR imposed on us, as well as to comply with Finnish legislation and other laws that may be applicable to us, as the case may be. For this purpose, we only use Personal Data to the minimum extent to fulfil our legal obligations.

Legal bases for our processing. As the controller of AppFollow Personal Data, we rely on the following legal bases under Article 6(1) of the GDPR:

  • performance of a contract (Article 6(1)(b)) – to enter into and perform our agreement with you, to set up and administer your Account, to provide the Service and the Consultancy Service, to send you administrative and service messages, and to invoice you;
  • your consent (Article 6(1)(a)) – for cookies and similar technologies that are not strictly necessary, and for marketing communications where consent is required;
  • our legitimate interests (Article 6(1)(f)) – to keep the Website and the Service secure and available, to troubleshoot errors and bugs, to produce aggregated statistics and to develop and improve our Service and Consultancy Service, to manage our customer relationships, and to market our own similar products and services to existing Customers. Where we rely on a legitimate interest, we have weighed that interest against your rights and freedoms, and you can object at any time as described under Your Rights, Entirely Yours below;
  • compliance with a legal obligation (Article 6(1)(c)) – to meet our accounting, tax and other statutory obligations.

Strictly necessary cookies are used on the basis of Article 5(3) of the ePrivacy Directive, which allows them without consent, together with our legitimate interest in the secure operation of the Website and the Service. For Customer’s Personal Data described in Section 2, the legal basis is determined by the Customer as the controller, not by us.

We do not take decisions based solely on automated processing that produce legal effects concerning you or that similarly significantly affect you, within the meaning of Article 22 of the GDPR. In the controller-side processing described in Section 1, our processing is limited to the purposes set out above together with Website analytics and cookies, and no artificial intelligence is applied to that data. We also never sell Personal Data to any third parties, for any purpose.

Please see Appendix 1 for a chart where we have collected all data categories and purposes for their collection and processing.

Do We Share Your Data?

They say sharing is caring, but that is not always the case when it comes to your Personal Data…

We think that here, transparency is the key: AppFollow uses processors and subprocessors, depending on AppFollow’s role in the relevant processing activity for purposes described in this Privacy Policy.

We use third-party service providers to support our activities. Where AppFollow acts as controller, those providers act as processors to the extent they process AppFollow Personal Data on our behalf. Where AppFollow acts as processor for Customer’s Personal Data, relevant providers act as subprocessors and may perform the processing activities described in the DPA and the applicable subprocessor list, including hosting, storage and other service functions required to provide the Service.

The current list of the subprocessors that process Customer’s Personal Data, the procedure by which we notify Customers of any intended change to that list, and the Customer’s right to object to a new subprocessor, are set out in and maintained under the DPA rather than in this Privacy Policy.

We also run our own business on ordinary business software, and the AppFollow Personal Data described in Section 1 is stored and processed in those internal systems. This includes, for example, our CRM and sales tools (such as Salesforce), our internal communication tools (such as Slack), our email and office software, our billing and invoicing tools, our customer support tools and our product analytics. The providers of these systems act as our subprocessors — they process the data only for us and on our instructions, under a data processing agreement, and they are not permitted to use it for their own purposes. The full list of subprocessors you can find in our Trust Center.

Using of subprocessors is always subject to the following:

📍the subprocessor is located within the EEA or a country with an equivalent level of personal data protection as determined by the European Commission, or such subprocessor has provided sufficient guarantees that the subprocessor in question processes personal information with the sufficient level of protection from the GDPR-point-of-view. Such a sufficient level is reached, for example, by agreeing about it by using the standard contractual clauses (SCCs) as issued by the European Commission; and

📜 such subprocessing is subject to the terms of an appropriate data processing agreement (DPA) between us and the subprocessor.

Further, we may share Personal Data with our current and future affiliates, which means entities that control, are controlled by, or are under the same controlling entity with us. We are sort of in the same club here, as our affiliates may use Personal Data in a manner set forth by the Privacy Policy.

AppFollow may also disclose Personal Data if we have an obligation to do so according to law, decree, regulation, order by a court or other official authority, or a similar action applicable to us, or if we are allowed to do so according to an agreement we have with a Customer, or in order to seek legal remedies or enforce our rights under such agreement. In these cases, we will only disclose Personal Data to the minimum extent necessary case-by-case, and in case of an agreement with a Customer, according to the clauses of the said agreement.

Psst! Our enthusiastic team is distributed with some members located outside the European Economic Area. They may also process Personal Data if it’s part of their job here at AppFollow. This is not a disclosure to a third party and it is not subprocessing: these esteemed colleagues are AppFollow’s own personnel and process the Personal Data on behalf of and in the name of AppFollow, not as a separate party of their own. They are bound by an appropriate confidentiality obligation, act only on our instructions, and have access only to the data their role actually requires. The place from which a colleague happens to work does not change where the Personal Data itself lives, e.g. the servers where that data is snuggled in.

Keeping Your Data Safe and Sound

We respect the principles of lawfulness, fairness and transparency; purpose limitation; data minimization; accuracy; storage limitation; integrity and confidentiality, and accountability when it comes to Personal Data. We are obliged by the GDPR to understand and abide by these principles, but we also think they are really cool to have. Meaning, we think they are not just words but rather really important things!

Here at AppFollow we have implemented appropriate technical, administrative and organizational measures in order to achieve many things, such as:

  • to be able to protect Personal Data the best we can
  • to ensure and to be able to demonstrate that we perform data processing in accordance with the GDPR
  • to prevent any unauthorized person from gaining access to computer systems processing Personal Data
  • to prevent any unauthorized reading, copying, alteration or removal of Personal Data
  • to prevent any unauthorized memory inputs as well as any unauthorized disclosure, alteration or erasure of stored Personal Data
  • to prevent unauthorized persons from using AppFollow’s systems by means of data transmission facilities
  • to ensure that authorized Users of Service or Consultancy Service have access only to such Personal Data that their access right refers
  • to ensure that our employees processing Personal Data are subject to a duty of confidentiality and only process Personal Data according to our instructions.

Personal data breaches. If a personal data breach happens, we move fast. Where AppFollow is the controller, we notify the competent supervisory authority without undue delay and, where feasible, no later than 72 hours after becoming aware of the breach, unless the breach is unlikely to result in a risk to your rights and freedoms; and where the breach is likely to result in a high risk to you, we also inform you without undue delay. Where AppFollow acts as a processor on a Customer’s behalf, we notify that Customer without undue delay after becoming aware of the breach, so that the Customer is able to meet its own obligations in time. Our notification will describe the nature of the breach, the categories and approximate number of data subjects and of records concerned, the likely consequences, the measures we have taken or propose to take, and a contact point from whom more information can be obtained. The applicable notification timelines and the required content of our notifications to Customers are set out in the DPA.

Despite all this, please keep in mind that the Internet (and functions working via it, such as email) are never (or at least until this moment in space and time have not been) completely free of errors or secure in a way that a computer-operated completely offline is (although they too can crash). Life is a risky business, as they say, but especially when it comes to Personal Data, it’s good and necessary to be aware of these things.

Please also note that this Privacy Policy applies solely to Personal Data collected and/or processed by AppFollow and does not cover other websites and services than our Website, even if there’s a link to such a website. If you go to another website, please familiarize yourself with the privacy policy located there. You can make another cuppa for that.

How Long Do We Keep Your Data For?

In case you’re trying to forget the look you had in the 80s, don’t worry – we probably won’t be able to remind you about that!

We retain Personal Data for the duration of the Account or of the contractual relationship. Once that relationship ends, certain categories of data may be retained for the periods necessary to comply with obligations laid down by law, to resolve disputes and to defend legal claims. The specific period depends on the category of data, the purpose of the processing and the applicable limitation period. To give a concrete example, accounting material is kept for the periods required by the Finnish Accounting Act (1336/1997): vouchers, correspondence concerning transactions and other supporting accounting material for at least six years after the end of the year in which the financial year ended, and financial statements, ledgers and the chart of accounts for at least ten years. For visitors of our Website, and for people who contact us without ever having an Account, the retention period follows the lifetime of each cookie as set out in our cookie banner, and a fixed period running from our last contact with you.

The necessity is most likely dictated by one of the following reasons:

  • storing the Personal Data is necessary for us to be able to fulfil the purpose for which said Data was collected, namely our contractual obligation with you and/or providing our Service or Consultancy Service to you
  • we have to store the Personal Data to comply with our legal obligations
  • we need the Personal Data to resolve a dispute
  • we need the Personal Data to be able to enforce our agreements

We check the Personal Data we have periodically and erase such parts we don’t need any more. Please note that instead of deleting, we may anonymize the Personal Data and keep it for statistical purposes. At this point, the Personal Data will stop being Personal Data, as after being anonymized, it is no longer possible to identify any Data Subject from or based on said information, directly or indirectly, and not even by connecting different pieces of information.

We may keep data longer than defined above, but only in such anonymized form that can no longer be connected or traced to any individual person, or even Father Christmas. This is done for statistics purposes. We thought we would mention this too, even though such anonymized data does not actually count as Personal Data, as no one can be identified from or on the basis of it.

In case you’re a Customer, and wish to delete your account earlier including all reviews data within that account, please don’t hesitate to contact us at legal@appfollow.io. Please note that deletion of such data will affect our capability of providing you Service.

Other Important Things not Quite Fitting Under Previous Headlines

1. It may be nice to know that our servers, where Personal Data is stored, are located within the EEA.

2. Hello young person! Please keep in mind that our Service and Consultancy Service are intended for legal entities, self-employed entrepreneurs and/or individuals above the age of 18. We do not on purpose collect any personal data from anyone younger than age 18. If you are a person under the age of 18, please have your parent or a legal guardian take a look at this with you. If you are the parent or a legal guardian of a person younger than age 18 reading this, and believe that AppFollow has collected Personal Data from or regarding such a person, please give us a shout at: legal@appfollow.io. We will be able to assist in deleting such Personal Data information from our files.

Your Rights, Entirely Yours

General. In case we collect or process your Personal Data, that makes you a data subject. If you as a data subject have a request relating to your rights, please send us an email at legal@appfollow.io. We will get to work and process your request without undue delay, and in any event within one (1) month. However, if necessary, and upon providing notice to you, this period of one (1) month may be extended by a further two (2) months.

The request will be handled free of charge. Only in the two situations allowed by Article 12(5) of the GDPR, namely where a request is manifestly unfounded or excessive, in particular because of its repetitive character, may we either charge a reasonable fee taking account of our administrative costs, or refuse to act on the request. If we do either of those things we will explain why and tell you how to complain. Separately, and as Article 15(3) of the GDPR expressly permits, we may charge a reasonable fee for any further copies of your Personal Data that you ask for beyond the first copy.

Please note, AppFollow will generally require data subjects to identify themselves in order to be able to handle requests regarding Personal Data. If we don’t know your name (or nickname, as the case may be), there’s unfortunately not much we can do. We will only ask you for the additional information we genuinely need in order to confirm who you are. And if we are not in a position to identify you from the data we actually hold, we will tell you so, rather than leaving your request unanswered.

Here are things you as a data subject can request from us:

Access. You have a right to see what we’re up to, in other words, you can request a copy of your Personal Data that is undergoing processing. The first copy is provided free of charge. We may charge a reasonable fee for further copies requested by you, taking administrative costs into account. The right to obtain a copy shall not adversely affect the rights and freedoms of others. Where necessary, we may redact information relating to third parties or protect confidential information rather than withhold your Personal Data as a whole.

Rectification. It’s a fancy word, and it means correction. You as a data subject have a right to request rectification of any inaccurate Personal Data concerning you. Please just give us a shout!

Erasure. You have a right to request the erasure of your Personal Data where any of the following applies: the data is no longer necessary in relation to the purposes for which it was collected; you withdraw the consent on which the processing is based and there is no other legal basis for it; you object to the processing under Article 21(1) of the GDPR and there are no overriding legitimate grounds, or you object to processing for direct marketing purposes; the data has been processed unlawfully; erasure is required in order to comply with a legal obligation under EU or Finnish law; or the data was collected in relation to the offer of information society services to a child. No need to mark deadlines for erasure in your calendar, as we periodically erase data that is no longer needed for the purpose it was collected for. However, this right is yours and you should exercise it if you feel it’s necessary. We’re here to help you with it.

Data portability. Where we process Personal Data that you have provided to us on the basis of your consent or for the performance of our contract with you, and that processing is carried out by automated means, you have a right to receive that data in a structured, commonly used and machine-readable form, and to have it transmitted directly to another controller where this is technically feasible.

Withdrawal of consent. Where our processing is based on your consent – for example cookies that are not strictly necessary, or marketing communications – you can withdraw that consent at any time, and withdrawing will be as easy as giving it was. Withdrawing your consent does not affect the lawfulness of the processing we carried out before you withdrew it, and it does not affect processing that rests on a different legal basis.

Right to restrict processing. You have a right to request the restriction of the processing of Personal Data relating to you in the following scenarios:

  • if you contest the accuracy of the data
  • if you think our processing is unlawful and instead of erasure wish for a restriction
  • if we no longer need the Personal Data but you require said data for the establishment, exercise or defence of legal claim
  • in case you have objected to the processing and it’s being verified whether we have legitimate ground that overrides yours

Right to object to direct marketing. You have an absolute right to object, at any time, to the processing of your Personal Data for direct marketing purposes, including any profiling to the extent that it relates to such marketing. There is no balancing test here and we do not get to argue: if you object, we stop. It is free of charge and we will not ask you why. You can do this by using the unsubscribe link in any marketing message, through your Account settings, or by emailing us at legal@appfollow.io. See also Us as Pen Pals – You can Opt Out below.

Right to object to processing. You have a right to object, at any time and on the ground relating to your particular situation (whatever that may be – we hope it’s good though), to processing Personal Data concerning you. We then have to demonstrate compelling legitimate grounds for the processing. If we don’t, we have to stop said processing.

Automated decision-making. You have a right not to be subject to a decision based solely on automated processing which produces legal effects concerning you or similarly significantly affects you. As explained under How We Use Your Data above, we do not take decisions of that kind.

Right to lodge a complaint with a supervisory authority. You don’t have to take our word for it. If you as a data subject think that processing of your Personal Data infringes your rights, you can lodge a complaint with a supervisory authority agency. You can do this with the supervisory authority in the EU or EEA country of your habitual residence, of your place of work, or of the place where you believe the infringement took place – for example the Agencia Española de Protección de Datos (AEPD) if you are in Spain. A list of all national supervisory authorities is available at https://www.edpb.europa.eu/about-edpb/about-edpb/members_en. The supervisory authority in Finland is the Office of the Data Protection Ombudsman – you can reach them via their website at www.tietosuoja.fi.

US State-Specific Privacy Rights

This section contains additional information relevant to residents of certain US states that have their own laws and regulations regarding data privacy, including the rights that may be available to residents of these states upon effective dates of the state laws and regulations.

Additional Information for California Residents (Effective 1 January 2023)

If you’re lucky enough to be enjoying the gentle waves of the Pacific and the California sun, please read carefully. This section provides additional details about the Personal Data we collect about California consumers, i.e. the Customer’s representatives and contact persons, Users of our Service or Consultancy Service, as well as visitors of our Website who are residents of California, and the rights which may be afforded to them under the California Consumer Privacy Act (as amended by the California Privacy Rights Act) or the “CCPA.”

For more details about the Personal Data we have collected over the last 12 months, including the categories of sources, please see the Personal Data and Sources of Personal Data section above or Appendix 1 below. We collect this information for the business and commercial purposes described in the How We Use Your Data section above or Appendix 1 below. We share this information with the categories of third parties described in the Do We Share Your Data? section above. We do not sell (as such term is defined in the CCPA) the Personal Data we collect (and will not sell it without providing a right to opt-out). Please note that we do use third-party cookies for our advertising purposes as further described in the Cookie Policy section below.

In regard to our role as a data controller, as described in the AppFollow Personal Data section above, if you are a California consumer, pursuant to the CCPA and subject to certain limitations, you may have the right to request, and to know and see, what Personal Data we have collected about you, including, the categories of Personal Data we have collected about you, the categories of sources from which the Personal Data is collected, the business or commercial purpose for collecting your Personal Data, the categories of third parties with whom we have disclosed your Personal Data, and the specific pieces of Personal Information we have collected about you. Additionally, you may have the right to request that we delete the Personal Data we have collected from you, to request that we correct inaccurate Personal Data, and to limit the use of sensitive Personal Data. You do have the right not to receive retaliatory or discriminatory treatment for inquiring or exercising the abovementioned rights.

However, please note that if the exercise of the abovementioned rights limits our ability to process Personal Data (such as in the case of a deletion request), we may no longer be able to provide you our Service or Consultancy Service or engage with you in the same manner.

In regard to our role as a data processor, as described in the Customer’s Personal Data section, we are not required to comply with a request directly from a reviewer of the Customer. However, we will provide assistance to a Customer with respect to the Customer’s response to a reviewer’s request, including, but not limited to, providing to the Customer the reviewer’s Personal Data in our possession.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at l. We will verify your request using the information associated with your account, including your email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

Additional Information for Virginia Residents (Effective 1 January 2023)

This section provides additional details about the Personal Data we collect about Virginia consumers, i.e. the Customer’s representatives and contact persons, Users of our Service or Consultancy Service, as well as visitors of our Website who are residents of Virginia, and the rights which may be afforded to them under the Virginia Consumer Privacy Act.

For more details about the Personal Data we have collected over the last 12 months, including the categories of sources, please see the Personal Data and Sources of Personal Data section above or Appendix 1 below. We collect this information for the business and commercial purposes described in the How We Use Your Data section above or Appendix 1 below. We share this information with the categories of third parties described in the Do We Share Your Data? section above.

In regard to our role as a data controller, as described in the AppFollow Personal Data section above, if you are a Virginia consumer, pursuant to the Virginia Consumer Privacy Act and subject to certain limitations, you may have the right to request, and to know and see, what Personal Data we have collected about you, the right to request that we correct inaccurate Personal Data, and the right to request that we delete the Personal Data we have collected from you, and the right to opt out of targeted advertising (as defined under Virginia law).

Virginia consumers may make a request pursuant to their rights under the Virginia Consumer Privacy Act by contacting us at legal@appfollow.io. We will verify your request using the information associated with your account, including your email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

Additional Information for Utah Residents (Effective 31 December 2023)

This section provides additional details about the Personal Data we collect about Utah consumers, i.e. the Customer’s representatives and contact persons, Users of our Service or Consultancy Service, as well as visitors of our Website who are residents of Utah, and the rights which may be afforded to them under the Utah Consumer Privacy Act. 

For more details about the Personal Data we have collected over the last 12 months, including the categories of sources, please see the Personal Data and Sources of Personal Data section above or Appendix 1 below. We collect this information for the business and commercial purposes described in the How We Use Your Data section above or Appendix 1 below. We share this information with the categories of third parties described in the Do We Share Your Data? section above.

In regard to our role as a data controller, as described in the AppFollow Personal Data section above, if you are a Utah consumer, pursuant to the Utah Consumer Privacy Act. and subject to certain limitations, you may have the right to request, and to know and see, what Personal Data we have collected about you, the right to request that we delete the Personal Data we have collected about you, and the right to opt out of targeted advertising (as defined under Utah law).

Utah consumers may make a request pursuant to their rights under the Utah Consumer Privacy Act by contacting us at legal@a. We will verify your request using the information associated with your account, including your email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

Additional Information for Colorado Residents (Effective 1 July 2023)

This section provides additional details about the Personal Data we collect about Colorado consumers, i.e. the Customer’s representatives and contact persons, Users of our Service or Consultancy Service, as well as visitors of our Website who are residents of Colorado, and the rights which may be afforded to them under the Colorado Privacy Act.

In regard to our role as a data controller, as described in the AppFollow Personal Data section above, if you are a Colorado consumer, pursuant to the Colorado Privacy Act and subject to certain limitations, you may have the right to request, and to know and see, what Personal Data we have collected about you, the right to request that we correct inaccurate Personal Data, and the right to request that we delete the Personal Data we have collected from you, and the right to opt out of targeted advertising (as defined under Colorado law).

Colorado consumers may make a request pursuant to their rights under the Colorado Privacy Act by contacting us at legal@appfollow.io. We will verify your request using the information associated with your account, including your email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

Additional Information for Connecticut Residents (Effective 1 July 2023)

This section provides additional details about the Personal Data we collect about Connecticut consumers, i.e., the Customer’s representatives and contact persons, Users of our Service or Consultancy Service, as well as visitors of our Website who are residents of Connecticut, and the rights which may be afforded to them under the Connecticut Data Privacy Act.

In regard to our role as a data controller, as described in the AppFollow Personal Data section above, if you are a Connecticut consumer, pursuant to the Connecticut Data Privacy Act and subject to certain limitations, you may have the right to request, and to know and see, what Personal Data we have collected about you, the right to request that we correct inaccurate Personal Data, and the right to request that we delete the Personal Data we have collected from you, and the right to opt out of targeted advertising (as defined under Connecticut law).

Connecticut consumers may make a request pursuant to their rights under the Connecticut Data Privacy Act by contacting us at legal@appfollow.io. We will verify your request using the information associated with your account, including your email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

Additional Information for Nevada Residents (Effective 1 October 2019)

If you are a Nevada consumer, i.e., a Customer’s representative or contact person, User of our Service or Consultancy Service, or a visitor of our Website who is a resident of Nevada, under the Privacy and Security of Personal Information Chapter of the Nevada Revised Statutes Section 603A (“603A”), we are required to provide you with the following:

  • we may collect certain covered information (as defined under Nevada Law) when you use or visit our website, Services or Consultancy Services, including, but not limited to first and last name, email address, and phone number;
  • we may share your covered information to third parties as described in the Do We Share Your Data? Section; and
  • third parties may collect covered information about your online activities over time and across different internet websites or online services when you use our Services or Consultancy Services.
Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined under Nevada law) to a person for that person to license or sell such information to additional persons. We do not engage in such activity; however, if you are a Nevada resident who has purchased Services or Consultancy Services from us, you may submit a request to opt out of any potential future sales under Nevada law by contacting us at legal@appfollow.io. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

Cookie Policy

Then to cookies. These are unfortunately not the kind you can eat but rather the kind made of letters and numbers and placed on your computer when you visit websites.

Cookies per se are not Personal Data, but they often contain Personal Data in the form of a unique ID for each user and may be linked directly or indirectly to a Data Subject when combined with other information. That’s why we thought it would be the clearest approach to include our Cookie Policy to our Privacy Policy.

We use cookies deposited on your computer when you visit our Website or access our Service. The cookies can be divided to marketing and analytics cookies, and to so-called essential cookies, without which the functionality of our Website and Service would be significantly lessened. The purposes for our cookie collection are to enable, develop and improve our Website, the Service and Consultancy Service, as well as for marketing and analytics purposes. The data collected by cookies will be processed according to this Privacy Policy, so no nothing new in that regard.

The cookies will identify your browser and operating system, as well as track your browser between active sessions and when accessing different parts of our Website and Service. Some parts of our Website and Service require the use of cookies to operate properly, such as logging in to our platform.

We also use cookies in order to obtain non-personal analytics data about the use of our Website, such as information of the website wherefrom you landed to our Website, the number of page views, your movements around on our Website and duration of time spent on our Website.

It’s an important reminder that you are in control, meaning you can block, delete or turn off cookies deposited on your computer any time you wish. This can be done by accessing the Settings section of the web browser of your choice.  That is a way of blocking or deleting cookies, though – it is not the way you give or refuse consent to them; for that, please use the cookie banner described below.  Please just keep in mind that our Website or Service will not work properly without some cookies.

You can also delete cookies any time by accessing the settings of your browser.

How consent to cookies actually works here. Continuing to browse our Website is not consent, and neither is leaving your web browser set to accept cookies. Cookies that are strictly necessary for our Website and Service to function are used without your consent, as Article 5(3) of the ePrivacy Directive permits. Every other cookie, including all marketing and analytics cookies, is placed only after you have given your consent through an explicit opt-in in the cookie banner on our Website, where you can accept or reject each category of cookies separately and where rejecting is just as easy as accepting. As nothing in life, this isn’t permanent: you can withdraw or change your consent at any time through the cookie settings link on our Website, and withdrawing is as easy as giving consent was. The banner also sets out, for each category, the cookies we use, what they are for, how long they last and which third parties are involved.

For more information about cookies, see for example allaboutcookies.org.

Us as Pen Pals – You can Opt Out

There are two different kinds of communications you may receive from AppFollow, and they work differently.

  • Marketing messages – things we think might be interesting to you, such as new features of our Service. Taking our Service or Consultancy Service into use is not, by itself, agreement to receive these. We send electronic marketing to individuals only where you have given us a separate, specific opt-in: a tick box that is never pre-ticked and is never bundled into your acceptance of our Terms and Conditions. There is one narrow exception, permitted by section 200 of the Finnish Act on Electronic Communications Services (917/2014): if you are already our Customer, we may send you marketing about our own products and services of the same kind, and marketing addressed to an organisation’s general contact address does not require prior consent. In every case, and in every single message, you get a simple and free way to say no.

  • Administrative and service messages – messages about your Account or about your use of our Service or Consultancy Service. We send these in order to perform our contract with you, not in order to market to you, so they are not affected by your marketing preferences

You may change your mind, and accordingly, you can change your choices regarding the types of communication you receive from us through your Account. You may, for example, opt out of our marketing emails by following the instructions provided in each email (we’ll be sorry to see you go!).

In case you access our Service by using certain desktop browsers or mobile applications, you may, with permission, receive push notifications. We have no control over these preferences, but they can be modified in the settings menu for the mobile application or the applicable browser.

Please note that we reserve the right to send you certain communications relating to your Account or use of our Service or Consultancy Service (for example, if you wish to invite new Users to use the Service or if there is a billing matter to be taken care of) via email and other means as made available by you. We’re not marketing here, we just wish to keep you updated on what's going on. These messages may be unaffected if you opt out from receiving marketing messages.

Questions or Concerns? Please Reach Out to Us

Should you have concerns or questions regarding this Privacy Policy, we’re more than happy to discuss it. Please feel free to contact us at: legal@appfollow.io. Alternatively, you’re more than welcome to write to us at: AppFollow.fi Oy, Bulevardi 21, 00180 Helsinki, Finland.

We would also like to remind you that in case you as a data subject find this Privacy Policy or our approach to privacy infringing your rights, you can contact a supervisory authority agency. That can be the authority in your own country of residence or work, or in the country where you believe the infringement took place – see Your Rights, Entirely Yours above. The supervisory authority in Finland is the Office of the Data Protection Ombudsman – you can reach them or lodge a complaint via their website at www.tietosuoja.fi.

Appendix 1 – Data Categories and Business Purposes

If you’re in a rush, we collected this chart for quick and easy access to what Personal Data we process and for which purpose.

AppFollow collects and processes the following Personal Data for which AppFollow is the data controller:

AppFollow Personal Data

Data subject

Category of Personal Data

Processing carried out by AppFollow

Legal basis

Retention

Categories of recipients

Representatives and contact persons of Customers

Name, email address, phone number, title

Performance of agreement, managing customer relations and identifying and being able to contact our customers

Art. 6(1)(f) legitimate interest in managing the customer relationship; Art. 6(1)(b) performance of a contract only where the data subject is personally a party to the contract

Duration of the contractual relationship, then only as needed for statutory obligations, disputes and legal claims

Hosting; CRM and sales tools; email and internal communication tools; billing and invoicing tools

Users of our Service or Consultancy Service (which may be the same people as representatives and contact persons above)

Name, email address, phone number, title, IP address, geographical location (country), social media profiles (in case connected by the User), any feedback potentially given by the User, social media account in case integrated by the User

Performance of agreement, i.e. providing our Service or Consultancy Service, providing the User with necessary communication about the Service, marketing (unless opted-out), analytics, troubleshooting possible errors or bugs

Art. 6(1)(b) performance of a contract where the User is personally a party to the contract; Art. 6(1)(a) consent for marketing and for non-essential cookies; Art. 6(1)(f) legitimate interest in providing and administering access for corporate Users, security, troubleshooting and aggregated analytics

Duration of the Account; server and troubleshooting logs for a short defined period; thereafter only in aggregated form

Hosting; CRM and sales tools; email and internal communication tools; customer support tools; product analytics

Publishers of applications/software (if private persons)

Name (collected from publicly available information posted on Application Stores)

Developing our Service by maintaining a rolling list of most popular applications available on Application Stores

Art. 6(1)(f) legitimate interest in developing our Service

For as long as the application concerned is included in the list

Hosting

Visitors of our Website

IP address, browser type and version, location (country), operating system and platform, language, cookie identifiers

Statistics on the number of visitors, marketing and analytics, and the secure operation and troubleshooting of the Website

Art. 6(1)(a) consent for cookies that are not strictly necessary; Art. 5(3) ePrivacy Directive together with Art. 6(1)(f) legitimate interest for strictly necessary cookies and secure operation

Lifetime of each cookie as set out in the cookie banner; server logs for a short defined period

Hosting; analytics providers; marketing and advertising providers (only where you have consented)

Customers and Users (Account data)

Details of the subscription (type, length, fee) and any feedback given by the User – Personal Data only where the Customer is an individual

Performance of agreement, administering the subscription, and improving our Service and Consultancy Service

Art. 6(1)(b) performance of a contract; Art. 6(1)(f) legitimate interest in improving the Service

Duration of the Account, then only as needed for disputes and legal claims

Hosting; CRM and sales tools; billing and invoicing tools

Customers and Users (Transactional data)

Amounts, dates and methods of payment (credit card or invoice) – Personal Data only where the Customer is an individual. We hold no card numbers and no bank account details

Invoicing, and compliance with our accounting and tax obligations

Art. 6(1)(b) performance of a contract; Art. 6(1)(c) compliance with accounting and tax obligations

Periods required by the Finnish Accounting Act (1336/1997): for six years for vouchers and supporting material, for ten years for financial statements and ledgers

Payment service provider / acquirer; accounting service providers; billing and invoicing tools

 

Customer’s Personal Data

Data subject

Category of Personal Data

Processing carried out by AppFollow

Publishers of applications/software (if private persons)

Name (collected from publicly available information posted on Application Stores)

Performance of agreement, i.e. providing our Service (by tracking apps selected by the Customer and Users)

Reviewers

Name/nickname, any personal data included in the review, geographical location (country), language, OS version and device details (only in Google Play, in case the reviewer has connected necessary integrations) (collected from publicly available information)

Performance of agreement, i.e. providing our Service, according to selections made by Customers and Users

For Customer’s Personal Data, the legal basis for the processing, the retention period and the instructions for processing are determined by the Customer as the controller, not by AppFollow. The subprocessors we engage for this processing, the applicable technical and organisational measures, the personal data breach notification arrangements and the audit and assistance rights are set out in the DPA.