Godar End User Privacy Notice
Last Update: March 8, 2024
a.
Ekatox Singapore Private Limited ("Ekatox",
"we", or "us") is committed to respecting your privacy. Ekatox recognizes and believes that data privacy is
important to all Internet users, and therefore we design and operate our
services in a privacy-first manner. This Godar
Privacy Notice sets out how we collect, store, process, transfer, share and use
information that identifies or is associated with you.
b.
Ekatox offers a Godar service (the "Godar Services") that enables developers of mobile
applications and device features using the Godar
Services (our "Customers") to provide contextual results and
intent-based links in their apps, giving their end users ("Users")
simplified access to completing an action (for example, to quickly navigate to
a deep page within a particular app).
c.
At a high level, our Godar Services help mobile application users navigate their
mobile devices with more relevant suggestions and improved search capabilities.
To provide these services, we collect certain device-level data (e.g.,
advertising identifier and IP address) and query data (e.g., "t",
"tw") from Users. We use this information
to provide and improve the Godar Services, as well as
to provide other Ekatox products and services, and
generally to serve or communicate with developers of mobile applications using
the Godar Services (our "Customers"). We
may also de-identify or aggregate data we collect through the Godar Services and use it for any purpose.
d.
We disclose information
to our service providers and Customers and also to comply with laws, to protect
ourselves and others, or as part of a business transaction. Users may opt out
of certain data collection by following the instructions in the YOUR CHOICES REGARDING
YOUR INFORMATION section below. If you choose not to provide or share such data, it may affect
or even disable certain features and functionalities of the Godar
Services. Because we provide technology that powers the Godar
Services to our Customers, they may use a different name to describe their use
of our Godar Services (for example, “Scout” or
“Finder”). Users should review the privacy policies of their mobile device
providers and mobile applications they use, which may give you additional
options or rights regarding how our Customers use Your
data.
e.
This Godar
End User Privacy Policy (the “Godar Privacy Policy”)
explains what information we use to provide the Godar
Services, and how we share and protect data we obtained through the Godar Services. Please read this Godar
Privacy Notice carefully to ensure that you understand how we collect, store,
use and disclose your personal information before you use the Godar Services. Please note that this Godar
Privacy Policy only applies to the Godar Services,
while Exatox also offers other services and apps,
each with its own applicable privacy policy.
2. INFORMATION WE COLLECT AND USE
a.
We collect information
from users through the Godar Services. We process
information in a way that is relevant for the purpose for which it was
collected as described below. We require that each Customer commit to share
with Ekatox only information that it has lawfully
obtained and that it has the right to share with Ekatox.
We strongly discourage Customers from sharing sensitive User information with
us, as such information is not necessary for the provision of the Godar Services. Software development kits (“SDKs”) and
application programming interfaces (“APIs”) include code that allows Customers
to integrate and use the Godar Services. The Godar Services SDKs and APIs collect the following
information when Customers use the SDKs and/or APIs in their mobile apps, some
of which is considered personal data under applicable law (in other words,
information that itself may identify a unique individual or can be linked back
to an individual). Below summarizes the information collected automatically by
the Godar Services and for what purposes this
information is being collected.
|
Information |
CollectedPurpose |
|
Advertising identifier (e.g., Google Ad ID or
IDFA) |
Used for device identification and serving
personalized results and advertising. |
|
IP Address |
Used to understand general location, and for
statistical purposes. |
|
Country Code |
This is the ISO country code equivalent for
the SIM provider’s country code, and is used to understand country-level
location. |
|
Device Locale (country, language) |
Used for customizing results and advertising
to the device’s country and language settings. |
|
Query |
Any query submitted by a User for purposes of
responding to the User’s queries. Queries may include information that
identifies an individual (for example, if a User
searches for a friend “John Smith” or for news about a particular celebrity)
as well as information that does not identify anyone (for example, “pizza
nearby” or “phone cases”). Queries may be Internet-based or device-based (for
example, to search for a contact or an app on a User’s
phone). For Internet-based queries, we collect the information described in
this table. For device-based queries, our SDK will collect and store
information locally on a User’s device (for example,
a User’s contacts or the apps stored on a User’s device), but Ekatox does not receive this data. |
|
Device Model |
Used to serve relevant results and
advertising, and for reporting. |
|
Device Manufacturer |
Used to serve relevant results and
advertising, and for reporting. |
|
Operating System |
Used to serve relevant results and
advertising, and for reporting. |
|
Operating System Version |
Used to serve relevant results and
advertising, and for reporting. |
|
Mobile Network Status (Carrier) |
Used to serve relevant results and
advertising, and for reporting. |
|
Screen Resolution |
Used to serve relevant results and
advertising, and for reporting. |
|
Screen Size |
Used to serve relevant results and
advertising, and for reporting. |
|
Godar Services Software Data |
Information about the Godar
Services software running on your phone, including version, package name, and
Customer (not User) information associated with software installation. |
|
Engagement Data |
Information relating to a User’s
interactions (e.g., impressions, clicks) with the Godar
Services, including query results, advertisements, and/or apps; used to
improve the Godar Services and for reporting. |
1.
In certain cases,
Customers have configured the Godar Services to
operate on a device without sending either the advertising identifier or query
to Ekatox servers. In such cases: the Godar Services will analyze information stored on your
mobile device to serve results and advertising. Such analysis will be conducted
within your device, and Ekatox does not collect such
data to conduct this analysis.
2.
Ekatox may momentarily read an
IP address for statistical purposes and to anonymously sync data from its
servers to improve on-device query results and advertising.
b.
In addition to the information we collect identified above, the Godar Services may otherwise analyze information stored on
your mobile device or accessible through your mobile device’s services to
provide more relevant results to and advertising for mobile app content in
response to queries. The analysis of such information accessible through your
mobile device will be conducted within your device, and Ekatox
does not collect such data to conduct this analysis.
c.
Customers may provide
information to us to help better direct advertising to their desired audiences
delivered through the Godar Services (“Customer
Data”). Ekatox processes Customer Data as a service
provider on behalf of its customers for the Godar
Services and will not use this Customer Data for other purposes.
d.
In some cases, Ekatox permits Customers to use the Godar
Services to deliver advertisements in connection with Users’ queries. When this
occurs, we may receive data from such Customers’ third-party service providers,
at Customers’ direction, regarding how those Customers’ end users interact or
engage with Customer’s advertisements (“Postback
Data”). Ekatox processes all Postback
Data it receives as a processor on behalf of each Customer that provides it,
and Ekatox uses that Postback
Data only to provide the Godar Services to the
Customer. Ekatox does not control the purposes or
means of processing the Postback Data by Customer,
and is not responsible for Customer’s collection, use or disclosure of Postback Data.
e.
Ekatox is the controller of
the personal information we hold about you in connection with your use of the Godar Services. This means that we determine and are
responsible for how your personal information is used.
f.
Exatox processes data
collected through the Godar Services for the
following purposes:
1.
to provide, maintain,
optimize, research, and improve the Godar Services,
including to develop the results for User queries and improve the relevance
and/or usefulness of the results;
2.
to better understand how
and from where Users come to click on certain deep links and what types of
links are popular;
3.
to serve advertisements
in connection with Users’ queries;
4.
to fulfill Customers’
and prospective Customers’ requests for the Godar
Services including processing data at the Customer’s direction and transferring
User data to them. Ekatox does not control how
Customers use information Ekatox shares with
Customers, and Users should read Customers’ privacy policies to understand how
Customers use information they receive from Ekatox;
5.
to use for internal and
Customer business purposes, including to support both the Godar
Services and other Ekatox products and services,
develop new products and services, market products or services, support the
products and services of our Customers, and as
permitted or required by applicable law; and
6.
to create reports based
on aggregated information, which is information that cannot be linked back to
any individual person or Customer, and share these reports with the public.
g.
We may aggregate and/or
de-identify the data we collect. After data has been aggregated and/or
de-identified, Ekatox does not use it to personally
identify an individual. We may use de-identified and/or aggregated data for any
purpose, including without limitation for research and marketing purposes, and
may also share such data with any third parties, including business partners,
Customers, and/or others.
h.
Where permitted by law
and our agreements with customers, and with your consent (to the extent
required by law), Ekatox may also use data collected
through other Ekatox services to enhance and tailor
results of User queries. Please see the applicable Ekatox
privacy policies to understand our privacy practices with respect to those Ekatox services.
3. SHARING INFORMATION WITH OTHER PARTIES
a.
In addition to the ways
described above, Ekatox may also share information
with others under the following circumstances:
1.
We may share your
information, including your personal information, within the Ekatox Group. This includes
other brands owned or controlled by Ekatox and other
entities owned by or under common ownership as Ekatox,
which also includes our subsidiaries (i.e., any entity we own or control) or
our ultimate holding company (i.e., any organization that owns or controls us)
and any subsidiaries it owns;
2.
We may share your
information, including your personal information, with third-party vendors, consultants and other service
providers who work for us and need access to information we collect to do that
work, including for cloud storage, data analysis, and project tracking. These
third parties are prohibited from using the information for purposes other than
performing services for us or to comply with applicable legal requirements.
3.
We may share your
information, including your personal information, with our Customers
and their agents, as described in this Godar Privacy
Policy.
4.
We may share your
information, including your personal information, with customers of other Ekatox services, including their vendors or agents, if
requested by the customer, for attribution purposes.
5.
We may share your
information, including your personal information, to comply with laws or to
respond to lawful requests and legal process, and in order to investigate,
prevent, or take action regarding suspected, or actual, prohibited activities,
including but not limited to fraud and situations involving potential threats
to the physical safety of any person.
6.
We may share your
information, including your personal information, to protect the rights and
property of Ekatox, our agents, Customers, Users, and
others including to enforce our agreements, policies, and any applicable terms
and conditions.
7.
We may share your
information, including your personal information, in connection with any company transaction or
during negotiation of any merger, sale of company assets, financing, or
acquisition of all or a portion of our business to another company.
b.
We require that our Customers utilize the Godar
Services responsibly and in accordance with certain terms and conditions. Ekatox is not responsible for the data practices of any of
our Customers through the Godar Services or
otherwise. Each Customer’s practices are subject to each Customer’s individual
privacy policy. Users should review the privacy policy of each Customer to
understand how that Customer treats User information collected through the Godar Services.
4. YOUR CHOICES REGARDING YOUR INFORMATION
a.
We will retain your
information for as long as needed to provide you the functionalities of the Godar Services and for thirty days thereafter for the
purpose of analyzing or further improving our technology, the Godar Services, after which the personal information will
be deleted or anonymized.
b.
Where available, you may
be able to modify what data will be sent to Ekatox by
(1) deleting the Customer app through which you use the Godar
Services, (2) modifying settings in the Customer app, or (3) resetting or
re-installing the Customer app or device software.
c.
Under applicable law, You have the right to access, rectify, erase and restrict
the processing of Your personal data. You also have the right to object to Ekatox’s processing of Your data, all in accordance with
applicable law. Because Ekatox cannot associate the
personal data collected via the Godar Services with a
particular individual, it is not reasonably possible for Ekatox
to verify the identity of any particular data subject. To comply with the
security requirements of certain applicable laws, in such circumstances we therefore
may refuse to process the data subject request and will inform You accordingly.
Ekatox does, however, provide mechanisms for
objecting to certain types of processing of Your personal data as set forth in
the User Choices section above.
d.
You have the right to
lodge complaints about our data processing activities by filing a complaint
with our Data Protection Officer who can be reached by the “Contact Us” section
below or with a supervisory authority.
5. SECURITY AND STORAGE OF INFORMATION
a.
Securing the information
provided by our Customers and collected through the Godar Services is important to us. Ekatox
has implemented industry-standard technical, administrative, and physical
safeguards to help protect the information on our servers against unauthorized
access, alteration, disclosure or destruction. You are responsible for
maintaining the security of Your devices and online accounts, such as not
sharing passwords to Your devices.
b.
Our Data Retention
Policy: Personal data collected via the Godar
Services are stored in an identifiable form for no more than 7 days, after
which they are removed or pseudonymized. Any and all pseudonymized logs are
deleted after 12 months, unless otherwise required by applicable law or
otherwise agreed between Ekatox and the Customer. Ekatox may retain information collected by the Godar Services beyond these periods for fraud prevention,
analysis, or response, or to protect the safety of Ekatox,
its Customers, Users, or the public.
c.
In the event that any
information under our control is compromised as a result of a breach of
security, we will take reasonable steps to investigate the situation and where
appropriate, notify those individuals whose information may have been
compromised and take other steps, in accordance with any applicable laws and
regulations.
a.
The Godar Services are not directed to children. We require
that Customers agree to not knowingly send to us data relating to any children
under 13 (or, in certain jurisdictions, under 16). If You believe that we might
have any information from or about a child under 13 (and in certain
jurisdictions under 16) in violation of this policy, please contact our Data Protection Officer at godar.survice@gmail.com, so that Ekatox can promptly
investigate and delete any inappropriately obtained information.
7. LINKS TO THIRD PARTY WEBSITES
a.
The Godar Services link to other websites and apps. These other
domains are not controlled by Ekatox, and we do not
endorse or make any representations about third-party websites, apps, or social
media platforms. We encourage You to read the privacy policies of each website
and application that You interact with. We do not endorse, screen, or approve, and
are not responsible for, the privacy practices or content of such other
websites or applications. Visiting these other websites or applications is at
Your own risk.
8. UPDATES TO THIS PRIVACY NOTICE
a.
We may change this
Privacy Policy at any time in our sole discretion. We will post all changes to
this Privacy Policy on this page and will indicate at the top of the page the
modified Policy’s effective date. If You have any questions or suggestions regarding
this Policy, please contact our Data Protection Officer by email at
godar.survice@gmail.com.
a.
If you have questions
about this Policy Notice, please contact Data Protection Officer by email at godar.survice@gmail.com.