AppCidify Privacy Policy

Effective Date: July 04, 2025

Welcome to AppCidify, a privacy-first telemetry platform built to enhance advertising performance without sacrificing user privacy or trust. This Privacy Policy explains in detail how we collect, process, store, and secure telemetry data collected from Windows-based systems via our lightweight telemetry agent.

1. Our Privacy Commitment

At AppCidify, privacy is not just a compliance requirement — it is a foundational principle embedded in every aspect of our service. We recognize that user trust is earned through transparency, respect, and robust protections that safeguard personal information at every stage of data collection, processing, and storage.

1.1 Core Privacy Principles

• Privacy by Design and Default: Our telemetry platform is architected from the ground up with privacy at its core. By implementing privacy-preserving technologies, minimizing data collection, and defaulting to the highest privacy settings, we ensure that user information is protected without sacrificing functionality.
• Transparency and User Empowerment: We are committed to clear, accessible communication about what data we collect, why we collect it, and how it is used. Users are empowered with intuitive controls to decide what telemetry data they share and when.
• Data Minimization: We only collect the minimal amount of telemetry data necessary to provide meaningful insights and improve advertising efficiency. Personally Identifiable Information (PII) is never collected or stored.
• Security First: Protecting data from unauthorized access, misuse, or breaches is paramount. We employ state-of-the-art encryption, rigorous access controls, and continuous monitoring to maintain a secure telemetry environment.
• Accountability and Compliance: We hold ourselves accountable to the highest standards of data privacy by strictly adhering to global privacy laws including GDPR, CCPA, and other regional regulations, and by subjecting our practices to regular independent audits.

1.2 Commitment to Anonymity

• Complete Anonymization: AppCidify’s telemetry agent is designed to remove all personally identifiable information before any data leaves the user’s device. Behavioral patterns are aggregated and anonymized to prevent tracing data back to individual users.
• Ongoing Privacy Enhancements: We continuously research and implement the latest anonymization techniques and privacy-enhancing technologies to strengthen our protections and adapt to emerging privacy threats.

1.3 User Rights and Control

• Full Opt-in/Opt-out Control: We respect user choice by providing clear, easy-to-use mechanisms to opt in or out of telemetry data collection at any time without degrading the core functionality of our service.
• Access and Transparency: Users and enterprise clients can access details about the data collected, how it is processed, and the insights derived, ensuring complete transparency.
• Data Correction and Deletion: We provide mechanisms for users to request correction or deletion of any telemetry data associated with their devices, honoring the right to erasure as mandated by privacy laws.

1.4 Continuous Improvement and Accountability

• Regular Privacy Audits and Assessments: Our privacy policies and practices undergo periodic reviews and audits by internal teams and independent third parties to ensure compliance and identify areas for enhancement.
• Employee Training and Awareness: All AppCidify employees and contractors receive comprehensive privacy and security training to maintain a culture of privacy-first thinking throughout the organization.
• Incident Response Preparedness: We maintain robust incident response protocols designed to quickly identify, contain, and remediate any potential data breaches or privacy incidents.
• Stakeholder Engagement: We actively engage with regulators, industry experts, privacy advocates, and our user community to stay aligned with evolving privacy expectations and to foster trust through collaboration.

1.5 Commitment to Ethical Data Use

• Purpose-Limited Use: Telemetry data collected through AppCidify is used solely to improve advertising effectiveness, optimize user experience, and enhance system security — never for discriminatory or intrusive purposes.
• Non-Commercialization of Data: We do not sell, trade, or rent telemetry data to third parties. Data sharing occurs only with vetted subprocessors strictly under contractual obligations to protect user privacy.
• Respect for User Expectations: We design our data practices to align with user expectations of fairness, transparency, and control, ensuring our telemetry solutions foster trust rather than skepticism.

By choosing AppCidify, users entrust us with valuable behavioral insights — and we commit to honoring that trust through uncompromising privacy protections, clear communication, and continual innovation in privacy-first telemetry.

2. Information We Collect

AppCidify is designed to collect telemetry data that is entirely anonymized and stripped of any personally identifiable information (PII). The purpose of this data collection is solely to support advertising efficiency, behavioral pattern analysis, system optimization, and aggregated performance reporting. We do not collect, process, or store data that could be used to identify individuals directly or indirectly.

2.1 Categories of Data We Collect

2.1.1 System Metadata

• Operating System Version: Includes OS family (e.g., Windows 10, 11), version numbers, build type (e.g., Home, Pro), and service pack info.
• System Architecture: 32-bit vs 64-bit, kernel type, and processor family (e.g., x86_64, ARM).
• Environment Flags: Whether the system is running in a virtual machine, sandbox, or containerized environment.
• Boot Time: System start time (relative, not timestamped) to infer uptime behavior without capturing absolute time data.
• Locale Configuration: Language, region, time zone, and input method preferences.

2.1.2 Application Usage Behavior

• Application Launch Patterns: Which applications were opened, how often, and session duration (aggregated by hash and not tracked individually).
• Focus Events: Whether a window remained in the foreground, how long it stayed active, and transition frequency.
• Clickstream Metrics: Total number of mouse clicks, scrolls, and keyboard input events (no actual keystrokes are recorded).
• Navigation Paths: General movement through UI panels or features, useful for determining which advertising features are most engaged with (no screen recordings or session replay).
• Inactivity Durations: Time periods where no meaningful input occurs to help measure engagement without user ID correlation.

2.1.3 Performance Diagnostics (Aggregated)

• CPU Load Averages: Relative percentage of CPU usage over fixed time windows (e.g., 15 seconds, 1 minute).
• Memory Consumption Patterns: Total memory used by foreground applications over time.
• Disk I/O Metrics: Number of read/write operations per app context, not tied to file names or directories.
• Network Throughput: Amount of data transmitted and received per session, categorized by application, not IP address or URL.

2.1.4 Ad Interaction Analytics

• Ad Impressions: When an advertisement asset was rendered, its position, and how long it remained visible.
• Ad Engagement: Whether a click occurred, hover duration, or view-through rate (without user identifiers).
• Session Path to Conversion: Aggregated flow of anonymized behavioral markers from app open to ad interaction.
• Contextual Factors: Whether ad engagement occurred during app startup, idle time, or specific feature usage.

2.2 Collection Context

Telemetry data is collected using our lightweight, Windows-native agent. This agent operates passively in the background and only activates when explicitly permitted by the user or system administrator. All data collection operates within strict parameters:

• Telemetry collection is event-triggered and rate-limited to avoid overcollection or performance issues.
• All data points are timestamped using relative time (e.g., "5 minutes after boot") to avoid absolute tracking of activity.
• Agent logs are ephemeral and do not persist beyond the transmission window unless error diagnostics are enabled for enterprise support.

2.3 What We Explicitly Do Not Collect

To ensure total privacy, our system is designed to ignore or redact the following data types at the point of collection:

• No User Identity Information: No usernames, real names, email addresses, phone numbers, SSNs, or account details.
• No Hardware Identifiers: We do not collect MAC addresses, device serial numbers, advertising IDs, UUIDs, or IMEIs.
• No IP Addresses: All connections are proxied through encrypted relay layers to remove all IP tracking.
• No File Content or Names: No documents, filenames, directories, or clipboard data are ever read or stored.
• No Screen Captures or Audio: We never capture screens, audio, or webcam feeds.
• No GPS or Precise Location Data: Geographic telemetry is limited to rough region inferred from system locale, not real-time geolocation.
• No Behavioral Fingerprinting: We do not create device or user profiles for persistent re-identification.

2.4 Anonymization and Hashing Practices

Even for non-PII data, we apply multiple layers of protection to prevent linkage attacks or user re-identification:

• One-Way Hashing: All strings (e.g., app names) are hashed with a rotating salt to prevent cross-session correlation.
• Bucketization: Continuous variables (e.g., time spent) are grouped into discrete ranges (e.g., 0–5 min, 5–15 min).
• Differential Privacy: Select analytic queries use noise injection techniques to prevent reverse engineering.
• Session Isolation: Each telemetry session uses a fresh ephemeral ID that cannot be tied to past activity.

These measures ensure that data collected through AppCidify’s telemetry agent can never be linked back to specific users or devices—even by AppCidify staff or infrastructure providers.

3. How We Use the Data

AppCidify collects telemetry data exclusively for legitimate business purposes related to advertising optimization, product performance, and system diagnostics. All data used is fully anonymized and processed in accordance with our strict privacy-first principles. No data is used for tracking, profiling, or decision-making at the individual level.

3.1 Primary Use Cases

The anonymized data we collect is used in the following ways:

3.1.1 Advertising Performance Optimization

• Ad Placement Efficiency: We analyze aggregate behavior to determine which ad formats, timing intervals, and placements yield higher engagement or lower bounce rates across campaigns.
• Contextual Delivery: Data helps identify the best contextual triggers for displaying an ad (e.g., idle app state vs. active input) to improve user relevance without using personal identifiers or history.
• Heatmap Modeling: Aggregated clickstream data is used to inform advertisers where interaction most often occurs in app interfaces (on a per-feature basis, not per-user).
• Reach and Frequency Capping: Behavioral telemetry informs how often an ad is shown per anonymized session group to reduce fatigue without persistent identifiers.

3.1.2 Product and Feature Insights

• Feature Utilization Trends: We measure which features or application flows are most frequently accessed across the entire user base, informing both advertisers and product designers.
• Session Flow Analysis: Insights into how users move through applications—from open to close—help developers improve the app’s flow and retention-related elements.
• Drop-Off Identification: We identify common points where users disengage with an app or close it shortly after an ad is shown, supporting optimization efforts.

3.1.3 System Diagnostics and Compatibility

• Platform Performance Monitoring: System telemetry (e.g., CPU load, memory usage) is used to ensure the telemetry agent itself does not degrade host system performance.
• Crash and Error Aggregation: Anonymous crash signatures are used to detect systemic incompatibilities, especially with edge-case OS builds or virtualized environments.
• Hardware Diversity Insights: Helps ensure campaigns and SDK integrations work properly across different system profiles (e.g., low-memory devices, legacy systems).

3.1.4 Statistical Modeling and Analytics

• Behavioral Pattern Modeling: Aggregated and anonymized usage patterns help build probabilistic models that infer general user behavior groups (e.g., short-session vs long-session users) without identifying individuals.
• Campaign Effectiveness Analysis: Metrics such as average ad duration, hover time, and scroll rate are correlated (in aggregate) with campaign performance metrics to validate content strategy.
• Predictive Testing: Anonymous data is used to forecast campaign response to new formats using A/B and multivariate testing under privacy-preserving conditions.

3.2 What We Never Do With the Data

While the data we collect is anonymized, we still impose strict internal prohibitions on certain types of usage to prevent misuse and preserve public trust:

• No Individual Profiling: We do not create profiles of users based on behavioral traits, usage history, or inferred preferences.
• No Cross-App or Cross-Device Correlation: Data collected from one application or session is never linked to another—each dataset exists independently and cannot be merged across devices or software ecosystems.
• No Automated Decision-Making: We do not use telemetry data to make decisions that affect an individual, such as content filtering, ad pricing, or algorithmic targeting.
• No Resale or Monetization of Raw Data: We do not monetize telemetry through resale, brokering, or data exchange marketplaces. Our monetization model is entirely based on subscription and service contracts with advertisers and enterprises.

3.3 Legal Basis for Processing (GDPR Article 6)

Under the General Data Protection Regulation (GDPR), our lawful bases for collecting and using this telemetry data include:

• Consent (Article 6.1.a): End-users and enterprises provide clear opt-in consent for telemetry collection, which can be revoked at any time via the agent UI or enterprise policy settings.
• Legitimate Interests (Article 6.1.f): We process anonymized telemetry to improve product quality and advertising performance in a way that does not override individual rights or freedoms.

3.4 Internal Data Governance Controls

All uses of telemetry data are governed by strict internal data policies and enforced through technical safeguards:

• Role-Based Access: Only a small number of authorized personnel can access aggregated analytics datasets, and only for specific job functions.
• Use-Case Boundaries: Engineering, marketing, and data science teams each operate in data silos with clearly defined usage permissions and oversight.
• Audit Trails: All access to telemetry data is logged and reviewed periodically as part of our internal privacy audits.

3.5 Enterprise Use and Visualization

For enterprise clients using AppCidify’s real-time analytics dashboards:

• All data visualizations are based on de-identified group-level aggregations (e.g., average session time by app version).
• Custom segments or filtering tools cannot isolate fewer than 1,000 anonymized sessions to prevent "data skimming."
• Exported reports contain no raw identifiers and are encrypted during transit and at rest.

3.6 Feedback Loop Improvements

Data is also used internally to improve the telemetry agent itself:

• We measure resource consumption and execution time across OS versions to reduce CPU/RAM impact.
• Error telemetry is aggregated to identify bugs or performance regressions in real-world deployments.
• Opt-out and consent flows are reviewed regularly using anonymized event trails to improve clarity and accessibility.

All usage of data is carefully scoped, documented, and validated against our internal privacy review process. If a new use case for the data arises, it undergoes a Data Protection Impact Assessment (DPIA) before deployment.

4. Data Anonymization and Encryption

At AppCidify, protecting user privacy is foundational. We implement rigorous anonymization and encryption protocols to ensure that all telemetry data collected remains completely confidential and cannot be traced back to any individual user or device. Below we outline the multiple layers of data protection we employ.

4.1 Data Anonymization Techniques

Before any telemetry data leaves the user’s device, it undergoes extensive anonymization processing. This includes:

• Removal of Personally Identifiable Information (PII): Our agent performs a pre-processing scrub that strips all forms of PII, including but not limited to usernames, email addresses, IP addresses, device IDs, MAC addresses, and any embedded identifiers within telemetry.
• Hashing with Rotating Salts: Any strings that could potentially identify software components (such as app names or feature identifiers) are hashed using cryptographically secure hash functions (e.g., SHA-256) combined with a rotating salt that changes periodically. This prevents cross-session correlation or replay attacks.
• Aggregation and Bucketization: Numeric and time-based telemetry values are grouped into discrete ranges or “buckets” (e.g., CPU load 0–10%, 10–25%, etc.) to prevent pinpointing individual behaviors or rare events that could deanonymize users.
• Differential Privacy: We implement differential privacy algorithms on sensitive aggregate queries, adding mathematically calibrated noise to the data. This ensures statistical results remain useful while mathematically guaranteeing the privacy of individual contributions.
• Ephemeral Session IDs: Each telemetry session is assigned a randomized ephemeral identifier that is never stored persistently and cannot be linked to any previous or subsequent session.
• Local Data Minimization: Data is minimized at the source — only the absolutely necessary telemetry points are collected, preventing over-collection of raw data that might increase risk.

4.2 Encryption Standards and Practices

Encryption is applied at every stage of data handling to secure telemetry from the user device to our data centers and throughout storage and processing:

• In-Transit Encryption: All data transmitted between the telemetry agent and AppCidify servers is encrypted using TLS 1.3, the latest version of the Transport Layer Security protocol. TLS 1.3 provides robust protection against interception, eavesdropping, and man-in-the-middle attacks.
• At-Rest Encryption: Telemetry data stored on our servers is encrypted using AES-256, a symmetric encryption standard widely recognized for its strength and reliability. Encryption keys are managed securely with hardware security modules (HSMs) and rotated regularly.
• End-to-End Encryption: In some deployment scenarios, we support full end-to-end encryption where data is encrypted on the user device and only decrypted within secure enclave environments on our servers, ensuring data remains inaccessible even to internal operators.
• Key Management: Encryption keys are generated, stored, and rotated in accordance with industry best practices and standards such as NIST SP 800-57. Access to encryption keys is strictly controlled and audited.
• Secure Transmission Protocols: We leverage forward secrecy cipher suites to ensure that past communications remain secure even if long-term keys are compromised.
• Zero Trust Infrastructure: Our network architecture is designed on zero trust principles, isolating data flows and requiring continuous verification for all access requests.

4.3 Anonymization Validation and Testing

To ensure that anonymization measures are effective and resilient, we perform ongoing validation using:

• Re-identification Risk Assessments: Regular internal testing simulates adversarial attacks attempting to re-identify anonymized data to verify the robustness of our hashing, bucketing, and noise-injection processes.
• Penetration Testing: External security firms conduct penetration tests on our telemetry pipelines and storage environments to identify any potential leakage points.
• Privacy Impact Assessments (PIA): We carry out PIAs during product development and feature updates to evaluate the privacy risks of data collection and processing workflows.
• Compliance Audits: We undergo periodic audits against GDPR, CCPA, and ISO/IEC 27001 standards to ensure ongoing adherence to privacy and security controls.

4.4 Data Lifecycle Encryption and Anonymization Controls

Our data protection does not end at collection and encryption but extends throughout the entire lifecycle of telemetry data:

• Data Ingestion: Data is immediately processed in-memory for anonymization before being persisted in any storage system.
• Data Processing: All analytics computations occur on anonymized datasets within secure, access-controlled compute clusters.
• Data Retention and Deletion: Encrypted telemetry data is retained only as long as necessary to fulfill analytics and compliance requirements, after which it is securely deleted with cryptographic erasure methods.
• Backup and Disaster Recovery: Backups of telemetry data are also encrypted and stored with strict access controls to prevent unauthorized recovery.

4.5 User-Controlled Encryption and Privacy

AppCidify empowers users and enterprises with control over privacy and encryption settings:

• Opt-In/Opt-Out Encryption Modes: Users can select from multiple telemetry collection modes with varying privacy levels, including full anonymization with end-to-end encryption or limited telemetry with local-only storage.
• Enterprise Key Management: Enterprise clients can integrate their own encryption key management systems (KMS) for enhanced control over encryption keys.
• Privacy-First Defaults: All default configurations prioritize maximum data minimization, anonymization, and encryption, requiring explicit user consent to enable broader data collection.

Through these comprehensive anonymization and encryption measures, AppCidify ensures that telemetry data remains secure, private, and compliant with global data protection regulations, reinforcing user trust and enabling smarter advertising insights without compromising privacy.

5. User Control and Transparency

At AppCidify, we prioritize empowering our users and enterprise clients with comprehensive control over their data and absolute transparency regarding our telemetry practices. We believe privacy is a fundamental right, and our systems are designed to ensure users are informed, involved, and in charge every step of the way.

5.1 Comprehensive User Consent Framework

• Informed Consent: We ensure that all telemetry data collection begins only after users provide informed and explicit consent. Our consent prompts use clear, jargon-free language outlining what data will be collected, how it will be used, and users’ rights.
• Layered Consent Options: Users can opt-in to different levels of data sharing, from minimal system diagnostics to full behavioral telemetry, with clear descriptions of the implications of each choice.
• Continuous Consent Management: Users can revisit and adjust their consent preferences at any time via the telemetry agent interface or through enterprise admin dashboards, promoting ongoing autonomy.
• Consent Withdrawal: Consent withdrawal is made easy, immediate, and effective, ceasing data collection without penalty or service degradation.
• Consent Records: We maintain secure, tamper-evident logs of all user consents and changes, allowing users to review their consent history upon request.

5.2 Granular Data Access and Sharing Controls

• Category-Based Sharing: Users control telemetry data sharing at the category level (e.g., system performance, app usage, advertising interaction) enabling precision control tailored to privacy preferences.
• Temporal Controls: Options to pause telemetry collection temporarily during sensitive periods or based on location or network environment (e.g., public Wi-Fi) enhance user security and control.
• Scope Restrictions: Users can restrict telemetry collection to specific applications or processes rather than broad system-wide monitoring.
• Real-Time Opt-Out: Opt-out changes take effect immediately, with visual confirmation and feedback to reassure users their preferences are honored in real time.

5.3 Transparency via Detailed Reporting and Dashboards

• Privacy Dashboards: Our user-facing telemetry agent includes a privacy dashboard that displays in real time what data is being collected, anonymized, and transmitted, along with summaries of how that data contributes to advertising insights.
• Activity Logs: Users can access detailed logs showing when and what telemetry data was collected, processed, and shared, including timestamps and data categories.
• Transparency Reports: We publish comprehensive, publicly accessible reports detailing aggregate telemetry volumes, anonymization practices, data retention policies, and security audits on a quarterly basis.
• Data Usage Explanation: Simple, non-technical explanations accompany all data visualizations and reports to demystify analytics processes and results.
• Regulatory Compliance Documentation: We provide clear documentation demonstrating how our telemetry practices meet or exceed GDPR, CCPA, and other relevant data protection laws, available on demand to users and partners.

5.4 User Rights and Data Portability

• Right to Access: Users can request comprehensive reports about the telemetry data associated with their account or device, presented in an accessible, anonymized format.
• Right to Rectification: If users provide additional information or preferences linked to telemetry, they can request corrections or updates.
• Right to Deletion: Users can request deletion of all telemetry data related to their device or account, including removal from backups and archives, within regulatory timeframes.
• Right to Restrict or Object: Users may limit specific uses of telemetry data or object to its processing for advertising purposes. We honor these requests promptly and provide feedback on any limitations resulting from restrictions.
• Data Portability: Where feasible, users can export their telemetry summaries, consent histories, and related settings in standard machine-readable formats (e.g., JSON, CSV) for personal use or transfer.

5.5 Enterprise Control Features and Delegated Management

• Centralized Consent Administration: Enterprises benefit from centralized dashboards allowing management of telemetry consent across all deployed devices, enabling consistent privacy policy enforcement.
• Role-Based Access Control (RBAC): Enterprise admins can delegate telemetry management rights with fine granularity, restricting access to sensitive controls based on roles and responsibilities.
• Policy Templates and Enforcement: Predefined privacy and telemetry policies can be applied at scale with enforcement mechanisms that ensure compliance with internal governance and external regulations.
• Custom Privacy Configurations: Enterprises can customize data retention durations, encryption key management options, and telemetry granularity to meet their specific compliance needs.
• Audit Trails and Compliance Reports: Detailed audit logs of consent and data processing activities are maintained and accessible to enterprise compliance teams for ongoing monitoring and regulatory audit support.

5.6 Ongoing Communication and Support

• Dedicated Privacy Support: Users and enterprises have access to a dedicated support team specializing in privacy, consent management, and data rights queries.
• Privacy Updates and Notifications: We proactively communicate changes to privacy policies, telemetry features, or security practices through emails, in-app notifications, and our website.
• Incident Response Transparency: In the event of any security incident affecting telemetry data, affected parties receive timely, clear notifications outlining impact, mitigation, and remediation steps.
• User Feedback Channels: Multiple feedback channels (in-app forms, email, forums) are available to capture user concerns and suggestions, supporting continuous privacy improvement.

AppCidify’s comprehensive user control and transparency framework not only meets but exceeds industry standards, ensuring that every user and enterprise partner can confidently participate in privacy-first telemetry that respects their rights and fosters trust.

6. Compliance

AppCidify is committed to maintaining the highest standards of data privacy and security by rigorously adhering to global legal and regulatory frameworks. Our Privacy-First Telemetry service is designed from the ground up to comply with all relevant data protection laws, industry standards, and best practices to safeguard user privacy and maintain trust.

6.1 Global Regulatory Compliance

• General Data Protection Regulation (GDPR): AppCidify fully complies with GDPR requirements, including principles of data minimization, purpose limitation, transparency, lawful processing, and user rights such as access, rectification, deletion, and data portability.
• California Consumer Privacy Act (CCPA) & California Privacy Rights Act (CPRA): We meet all CCPA/CPRA obligations, offering California residents enhanced privacy rights such as the right to know, delete, opt-out of sale (where applicable), and nondiscrimination.
• Other Regional Privacy Laws: Compliance efforts extend to data protection laws worldwide, including Brazil’s LGPD, Canada’s PIPEDA, Australia’s Privacy Act, and other emerging frameworks.
• Children’s Privacy Protections: AppCidify adheres to COPPA (Children’s Online Privacy Protection Act) and equivalent laws, ensuring parental consent processes and restricted data collection from minors.

6.2 Data Protection and Privacy by Design

• Built-In Privacy Safeguards: Privacy and data protection principles are integrated at every stage of product design and development, following the “Privacy by Design” approach mandated by GDPR and industry best practices.
• Data Minimization: We collect only the telemetry data strictly necessary to deliver our service and optimize advertising insights, reducing privacy risks.
• Strong Anonymization: As detailed earlier, data is anonymized and aggregated to prevent personal identification, further strengthening compliance with privacy laws.
• Regular Privacy Impact Assessments (PIAs): We conduct PIAs for new features, deployments, and updates to identify and mitigate privacy risks proactively.

6.3 Security Standards and Certifications

• ISO/IEC 27001 Certification: Our information security management system (ISMS) is certified to ISO/IEC 27001 standards, ensuring robust, auditable controls around data confidentiality, integrity, and availability.
• Data Security Frameworks: AppCidify follows NIST Cybersecurity Framework guidelines and applies OWASP security practices in software development.
• Encryption and Key Management: All telemetry data is encrypted in transit and at rest with AES-256 and TLS 1.3, with secure key management practices audited regularly.
• Regular Security Audits and Penetration Testing: Independent third-party firms conduct comprehensive audits and penetration tests to identify vulnerabilities and validate our security posture.

6.4 Data Subject Rights Management

• Efficient Request Handling: We have established internal processes and dedicated teams to promptly address data subject requests such as access, correction, deletion, restriction, and portability.
• Verification Protocols: Identity verification procedures ensure that personal data is only disclosed or modified upon legitimate requests from verified users or authorized representatives.
• Automated and Manual Controls: Our systems combine automated workflows and manual oversight to maintain accuracy, compliance, and responsiveness to data subject rights.

6.5 Data Processing Agreements and Third-Party Compliance

• Processor and Sub-Processor Agreements: We maintain detailed Data Processing Agreements (DPAs) with all third-party service providers and subprocessors to ensure they meet or exceed our privacy and security standards.
• Due Diligence: Third parties undergo thorough privacy and security due diligence before onboarding, including compliance verification, risk assessments, and contractual commitments.
• Continuous Monitoring: Ongoing audits and monitoring of third-party compliance minimize risks associated with subcontracted data processing.

6.6 Compliance Training and Awareness

• Regular Staff Training: All AppCidify employees undergo mandatory, recurring training on data privacy, security practices, incident response, and regulatory requirements.
• Privacy Champions: Dedicated privacy officers and champions lead internal governance and ensure privacy considerations are embedded throughout organizational processes.
• Incident Response Drills: We perform periodic simulations and drills to prepare for potential data breaches or compliance incidents, ensuring swift and effective response.

6.7 Regulatory Engagement and Transparency

• Proactive Communication: We maintain open channels with relevant regulatory authorities and promptly report any incidents or inquiries as required by law.
• Audit Facilitation: AppCidify cooperates fully with regulatory audits and investigations, providing timely and transparent information.
• Privacy Policy Updates: We regularly review and update our privacy policies to reflect changes in law, technology, or business practices, with clear user notification.

Through these comprehensive compliance efforts, AppCidify ensures that our Privacy-First Telemetry service not only meets but often exceeds legal obligations and industry standards. This commitment protects our users, supports ethical advertising, and fosters trust across all stakeholders.

7. Data Retention

At AppCidify, we take data retention seriously, balancing the need to provide valuable telemetry insights with our commitment to user privacy and compliance with data protection regulations. Our data retention policies ensure that telemetry data is stored only for as long as necessary to fulfill legitimate business purposes, legal obligations, and user preferences.

7.1 Retention Principles

• Purpose Limitation: Telemetry data is retained strictly for specific, legitimate purposes such as enhancing advertising effectiveness, improving product performance, and complying with legal requirements.
• Data Minimization: Only the minimum necessary telemetry data is retained, with all personal identifiers removed or anonymized to reduce privacy risks.
• Retention Periods: We define and enforce specific retention periods for different types of telemetry data, based on sensitivity, usage needs, and regulatory mandates.
• Regular Data Purging: Automated processes routinely purge telemetry data that has exceeded its retention period, ensuring no unnecessary data is stored.

7.2 Types of Data and Retention Durations

Data Type	Description	Retention Period	Retention Rationale
Aggregated Behavioral Telemetry	Anonymous, aggregated data on user interactions and ad campaign performance.	Up to 24 months	Supports longitudinal analysis of advertising effectiveness and trend detection.
System Performance Metrics	Data on device and application performance without personal identifiers.	Up to 12 months	Used for troubleshooting, optimization, and improving user experience.
Consent and Opt-In Records	Logs of user consent status and changes.	Up to 5 years	Compliance with legal obligations and audit requirements.
Security and Access Logs	Records of access to telemetry data and security events.	Up to 1 year	Supports incident response, audits, and security monitoring.
Transactional and Billing Data (if applicable)	Information related to service billing and subscriptions.	Up to 7 years	Compliance with financial and tax regulations.

7.3 Anonymized Data and Long-Term Retention

• Permanent Anonymization: Once telemetry data has been anonymized to prevent any possible re-identification, it may be retained indefinitely in aggregated form for research and analytical purposes.
• Continuous Monitoring: We continuously evaluate anonymization techniques to ensure compliance with emerging privacy standards and prevent any risk of data linkage.
• Ethical Use: Long-term anonymized data is used solely to improve advertising strategies and platform development, never to identify individual users.

7.4 User-Initiated Data Deletion and Retention Overrides

• Right to Erasure: Users can request deletion of all telemetry data associated with their device or account, including removal from active systems and backups within legally mandated timeframes.
• Immediate Effect: Upon receipt of a valid deletion request, we prioritize data removal to ensure no further processing occurs.
• Retention Overrides: In cases where legal requirements necessitate extended retention (e.g., compliance investigations), users are informed about the rationale and duration.
• Data Minimization in Backups: Backups are encrypted and stored securely; any deleted user data is purged from backup copies during routine maintenance cycles in line with data minimization principles.

7.5 Data Retention Governance and Review

• Policy Review Cycles: Our data retention policies are reviewed at least annually, or more frequently as laws or business needs evolve.
• Cross-Functional Oversight: Data retention practices are overseen by a cross-functional team including privacy officers, legal counsel, and security experts to ensure alignment with compliance and risk management goals.
• Automated Enforcement: Retention periods are enforced via automated lifecycle management systems that flag and delete expired data without manual intervention.
• Audit and Compliance Checks: Regular audits verify adherence to retention policies, with findings reported to senior management and external regulators as required.

7.6 Communication and Transparency Around Retention

• Clear User Information: Users are informed about retention periods and practices through our Privacy Policy, onboarding documentation, and consent interfaces.
• Data Retention Notices: When users access their privacy dashboard, they receive notifications regarding upcoming data deletion or retention milestones relevant to their telemetry data.
• Retention Changes: Any significant changes to data retention practices are communicated promptly via email, in-app alerts, or website announcements.

By implementing these rigorous data retention policies, AppCidify ensures a balanced approach that respects user privacy, complies with applicable laws, and supports the delivery of valuable, privacy-first telemetry insights.

8. Third Parties and Subprocessors

AppCidify collaborates with trusted third-party service providers and subprocessors to deliver and enhance our Privacy-First Telemetry service. We are committed to ensuring that these relationships uphold the same rigorous standards of data privacy, security, and compliance that we maintain internally.

8.1 Definition and Role of Third Parties and Subprocessors

• Third Parties: Entities outside AppCidify who provide services such as cloud hosting, analytics, security, customer support, and other operational functions essential to our telemetry platform.
• Subprocessors: Subcontractors engaged by our third-party service providers that may have access to telemetry data to perform specific tasks on our behalf.
• Limited Access: All third parties and subprocessors receive access strictly limited to the data necessary for their defined functions, and only under binding contractual obligations.

8.2 Due Diligence and Selection Criteria

• Privacy and Security Evaluation: Before onboarding any third party or subprocessor, AppCidify conducts comprehensive due diligence to assess their data protection policies, security controls, regulatory compliance status, and past incident history.
• Risk Assessment: We perform detailed risk assessments focusing on data confidentiality, integrity, availability, and the potential impact of any data breaches or misuse.
• Compliance Requirements: Third parties must demonstrate compliance with GDPR, CCPA, and other relevant regulations applicable to their operations and the data they handle.
• Reputation and Reliability: Preference is given to vendors with proven track records, recognized certifications (e.g., ISO 27001, SOC 2), and strong industry reputation.

8.3 Contractual Safeguards and Obligations

• Data Processing Agreements (DPAs): All third parties and subprocessors sign DPAs that clearly define their responsibilities, data handling protocols, security measures, and breach notification requirements.
• Confidentiality Clauses: Contracts include strict confidentiality clauses prohibiting unauthorized use, disclosure, or retention of telemetry data.
• Audit Rights: AppCidify reserves the right to audit third parties to verify compliance with contractual and regulatory obligations at any time.
• Termination and Data Return/Destruction: Agreements mandate secure data return or certified destruction of telemetry data upon contract termination or upon request.

8.4 Categories of Third Parties and Their Functions

• Cloud Service Providers: Host telemetry data securely using encrypted storage and network infrastructure with robust physical and logical security controls.
• Analytics and Reporting Vendors: Process anonymized telemetry data to generate aggregated insights and performance metrics without accessing personally identifiable information.
• Security and Monitoring Services: Assist in intrusion detection, vulnerability management, and security incident response by analyzing telemetry logs and system events.
• Customer Support Platforms: Help manage user inquiries and support tickets, with access limited to relevant data required to resolve issues.
• Compliance and Audit Consultants: Provide independent assessments, audit support, and regulatory guidance to ensure ongoing adherence to privacy and security standards.

8.5 Data Transfer and International Compliance

• Cross-Border Transfers: Telemetry data transferred outside the user’s jurisdiction is handled in strict accordance with applicable data transfer regulations, including GDPR’s Standard Contractual Clauses (SCCs) and other approved mechanisms.
• Data Localization Requirements: Where applicable, AppCidify works with subprocessors to store or process data within specific geographic regions to meet data sovereignty requirements.
• Encryption in Transit and At Rest: All data transfers to third parties are encrypted end-to-end, ensuring confidentiality and integrity throughout transmission and storage.

8.6 Monitoring and Continuous Compliance Assurance

• Ongoing Audits: AppCidify performs regular audits of third-party subprocessors, reviewing security certifications, compliance reports, and operational controls.
• Incident Management: Third parties must report any security incidents or breaches involving telemetry data immediately, enabling coordinated response and mitigation.
• Performance Reviews: Vendor performance, including compliance and security adherence, is reviewed periodically to identify any risks or areas for improvement.
• Termination for Non-Compliance: Contracts include provisions allowing AppCidify to terminate relationships if third parties fail to maintain agreed-upon privacy and security standards.

8.7 Transparency and User Information

• Public Subprocessor List: We maintain and regularly update a publicly accessible list of all subprocessors involved in processing telemetry data, including their roles and locations.
• User Notifications: Users are informed proactively about any significant changes to our third-party ecosystem, including additions or removals of subprocessors.
• Opt-Out Provisions: Where feasible, users and enterprise clients may opt out of specific third-party data sharing through the telemetry agent or administrative settings.

Through meticulous management of third parties and subprocessors, AppCidify ensures that our Privacy-First Telemetry platform remains secure, compliant, and trustworthy, providing users with confidence that their data is handled responsibly at every stage.

9. Children’s Privacy

Protecting the privacy and safety of children is a paramount concern at AppCidify. We understand that minors require special protections under various laws and regulations, and we are fully committed to adhering to these requirements to prevent the unauthorized collection or use of telemetry data from children.

9.1 Age Restrictions and Service Eligibility

• Minimum Age Requirement: Our Privacy-First Telemetry service is not intended for use by individuals under the age of 16 (or the applicable minimum age in their jurisdiction).
• Age Verification: While our telemetry agent collects anonymous behavioral data without personal identifiers, we employ reasonable measures to avoid knowingly collecting data from minors.
• Parental Consent: In jurisdictions where parental consent is legally required (such as the U.S. under COPPA, or the EU under GDPR), we do not knowingly process telemetry data from children without verifiable parental consent.

9.2 Compliance with Children’s Privacy Laws

• Children’s Online Privacy Protection Act (COPPA): AppCidify complies fully with COPPA, which regulates online collection of data from children under 13 in the United States, by implementing strict consent and data minimization policies.
• General Data Protection Regulation (GDPR) - Article 8: For users in the European Union, we respect the GDPR’s stipulation that children under the age of 16 (or lower age set by member states) require parental consent for data processing.
• Additional Local Laws: We monitor and comply with other regional and national children’s privacy laws, including the UK’s Age-Appropriate Design Code, Canada’s CASL, Australia’s Privacy Act, and others.

9.3 Data Collection Limitations for Children

• No Collection of Personally Identifiable Information (PII): AppCidify’s telemetry system is designed to exclude all PII by default, and this restriction is strictly enforced for any data that could relate to minors.
• Anonymous Behavioral Patterns Only: Only anonymized, aggregate behavioral telemetry is collected to prevent identification of any individual, especially children.
• No Targeted Advertising to Children: Telemetry insights are never used to create targeted advertising profiles or campaigns aimed at minors, ensuring ethical advertising practices.

9.4 Parental Controls and Rights

• Parental Consent Management: Where applicable, parents or legal guardians have mechanisms to provide, review, or revoke consent for telemetry data collection related to their children.
• Data Access and Deletion Requests: Parents can request access to any telemetry data collected from their children and request its deletion at any time through our support channels.
• Educational Resources: AppCidify provides clear, accessible information to parents and guardians about our data practices and how they can control their children’s data privacy.

9.5 Security Measures to Protect Children’s Data

• Strict Access Controls: Access to any telemetry data potentially associated with children is highly restricted within AppCidify, limited only to authorized personnel trained on children’s privacy.
• Encryption and Anonymization: All telemetry data is encrypted in transit and at rest, and anonymization techniques are rigorously applied to eliminate any risk of re-identification.
• Regular Privacy Audits: We conduct specialized audits focused on children’s privacy to ensure compliance with legal standards and continuous improvement of protective measures.

9.6 Handling Incidents Involving Children’s Data

• Immediate Incident Response: In the unlikely event of a data breach involving telemetry data potentially linked to children, AppCidify initiates rapid response protocols to mitigate harm and notify affected parties and regulators as required.
• Regulatory Reporting: We comply with all applicable laws regarding the timely reporting of data breaches or incidents involving children’s data to regulatory authorities and affected parents or guardians.
• Remediation and Prevention: Post-incident analyses are conducted to identify root causes and implement enhanced safeguards to prevent recurrence.

9.7 Transparency and Ongoing Commitment

• Clear Privacy Notices: Our Privacy Policy and user communications include dedicated sections on children’s privacy to ensure transparency.
• Continuous Monitoring: We stay abreast of evolving laws and best practices related to children’s data protection and adapt our policies accordingly.
• Community Engagement: AppCidify engages with industry groups, child advocacy organizations, and regulatory bodies to promote privacy-first telemetry and ethical data use practices for minors.

By prioritizing children’s privacy with rigorous controls, legal compliance, and transparency, AppCidify ensures our telemetry service respects and protects the most vulnerable users, fostering a safe and trustworthy digital environment for all.

10. Changes to This Policy

AppCidify is committed to maintaining transparency and keeping our users informed about how we protect their privacy. As part of this commitment, we may update this Privacy Policy periodically to reflect changes in our practices, regulatory requirements, or technological advancements.

10.1 Reasons for Policy Updates

• Legal and Regulatory Changes: To comply with new or updated privacy laws and regulations such as GDPR, CCPA, or other regional frameworks that impact how we collect, process, or protect data.
• Technological Enhancements: To incorporate new privacy-enhancing technologies or security measures that improve data protection and user control.
• Service Modifications: To reflect changes in our telemetry service features, data collection methods, or partnerships with third parties and subprocessors.
• Feedback and Best Practices: To integrate user feedback, industry best practices, or findings from privacy audits and assessments.

10.2 Notification and Communication of Changes

• Advance Notice: We aim to provide users with advance notice of significant changes whenever possible, typically at least 30 days before the changes take effect.
• Multiple Notification Channels: Notifications may be delivered via email, in-app messages, dashboard alerts, or through prominent notices on our website.
• Summary of Key Changes: Communications will include a clear, concise summary of the most important changes, enabling users to quickly understand how updates affect their data privacy.
• Updated Policy Publication: The full updated Privacy Policy will always be available on our website, with the revision date clearly indicated at the top of the document.

10.3 User Rights and Actions Following Policy Changes

• Review and Consent: Continued use of the AppCidify service after the effective date of updated policies constitutes acceptance of the changes.
• Right to Object or Opt-Out: Where applicable, users retain the right to opt out of certain data processing activities or unsubscribe from telemetry collection consistent with the updated policy provisions.
• Data Access and Deletion: Users may request access to their telemetry data or request deletion if they do not agree with the new policy terms, subject to any legal or operational constraints.
• Contacting Us: We encourage users to contact our privacy team for any questions, concerns, or requests regarding policy changes via the contact information provided below.

10.4 Policy Versioning and Record Keeping

• Version Control: Each version of the Privacy Policy is archived and timestamped, allowing users and regulators to review the history of changes.
• Transparency of Past Policies: Historical versions may be made available upon request to demonstrate our commitment to accountability and transparency.
• Documentation of User Consents: We maintain secure records of user consents, opt-ins, and opt-outs linked to specific policy versions to ensure legal compliance and auditability.

10.5 Commitment to Ongoing Privacy Excellence

• Proactive Privacy Culture: AppCidify is dedicated to fostering a proactive culture of privacy, regularly reviewing and refining our policies beyond mere compliance.
• User-Centric Approach: We prioritize user rights, convenience, and clear communication to ensure privacy policy changes enhance user trust rather than create confusion.
• Collaboration with Stakeholders: Our policy update process includes engagement with privacy experts, legal counsel, and user feedback to continuously align with evolving privacy standards.

By transparently managing changes to this Privacy Policy, AppCidify ensures users remain informed and empowered to make choices about their telemetry data and privacy preferences.

11. Contact Us

Your privacy is our priority, and we are here to assist you with any questions, concerns, or requests related to your personal data, telemetry information, or this Privacy Policy. We encourage you to reach out to us through the appropriate channels listed below for prompt and effective support.

11.1 General Customer Support

For general inquiries, technical assistance, or support related to our telemetry service, please contact our Customer Support team:

• Email: support@appcidify.fr
• Phone: +1 (800) 555-1234 (Available Monday–Friday, 9 AM – 6 PM EST)
• Support Portal: https://support.appcidify.fr

11.2 Privacy and Data Protection Inquiries

If you have any questions or requests specifically about your privacy rights, data access, correction, deletion, or any concerns regarding our compliance with privacy laws, please contact our dedicated Privacy Team:

• Email: privacy@appcidify.fr
• Data Protection Officer (DPO): For GDPR-related inquiries or complaints, contact our appointed Data Protection Officer at:
• Email: dpo@appcidify.fr
• Postal Address: AppCidify Data Protection Officer, 123 Privacy Blvd, Suite 400, Seattle, WA 98101, USA

11.3 Reporting Data Privacy or Security Incidents

If you suspect a data breach, unauthorized access, or any security issue involving your telemetry data or our services, please notify us immediately so we can take swift action:

• Incident Response Email: security@appcidify.fr
• 24/7 Security Hotline: +1 (800) 555-SECURE (732-873)

11.4 Contacting Regulatory Authorities

In addition to contacting us directly, you have the right to lodge complaints or inquiries with relevant data protection authorities, especially if you believe your privacy rights have been violated. Below are key regulatory contacts:

• European Union (GDPR): European Data Protection Board and your local Data Protection Authority (DPA). Find your DPA here: https://edpb.europa.eu/about-edpb/board/members_en
• California (CCPA): California Attorney General's Office – Privacy Enforcement and Protection Unit: https://oag.ca.gov/privacy
• United States Federal (COPPA and other laws): Federal Trade Commission (FTC): https://www.ftc.gov/

11.5 Feedback and Suggestions

We value your feedback and suggestions on how we can improve our privacy practices and service experience. Please send your comments to:

• Email: feedback@appcidify.fr

11.6 Our Commitment to Prompt Responses

We aim to respond to all inquiries promptly, typically within 3 business days. For urgent matters, especially related to security incidents or data breaches, please use the dedicated security contact channels.

Thank you for trusting AppCidify with your telemetry and privacy. We are dedicated to protecting your data and supporting your rights at every step.

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Last updated: July 04, 2025