Privacy Policy

Last modified: November 27, 2023

At SEVEN Networks, LLC (“SEVEN”, “us,” “our,” or “we”) we recognize and respect your privacy. We have created this Privacy Policy (the “Policy”) to explain our privacy practices regarding the information that we collect from you through the AdClear, Dubbel, or our other mobile applications (the “App”). This Policy explains how SEVEN and its affiliates and subsidiaries (“Affiliates”) collect, use, disclose, and protect this information. This Policy also explains your choices regarding our information practices. If you have any questions, please contact us at support@seven.com. The Policy applies only to the information that we collect from you through the App. This Policy does not apply to the information we collect from visitors to our websites or information collected by SEVEN through other sources.

 

Policy Highlights

 

Aspects of this Privacy Policy are highlighted below only for your convenience. These highlights do not substitute, replace, or override any aspect of the full Privacy Policy.

Information collection	When you use the App, you choose to route some or all of your device's data traffic through or to, the App. We automatically collect some information routed through the App, such as information about your device, mobile applications, and data usage. You also may provide us with certain personal information when you use the App.
Use of information	We use the information we collect to provide the App and its services to you, analyze usage of our App and other applications on your device, to improve the App, and communicate with you.
Sharing information	Other than the limited circumstances described in this Policy, we do not make your personal information available to third parties unless the information sharing is described to you at the point of collection or we obtain your consent.
Your choices	You may choose not to provide the personal information we request. However, not providing information we request may restrict your ability to use certain App features. If you do not wish for the App to collect information about you in accordance with this Privacy Policy you should refrain from using the App and delete the App from your device. Under certain circumstances, you may make certain choices related to your information, such as requesting access to your information or requesting that we delete it.
Security	We maintain safeguards to help protect against loss, misuse, unauthorized access, disclosure, alteration, or destruction of the information we receive.
International transfers	We may store and process information, including through third-party or Affiliate hosting services, in the United States, EEA, and other international jurisdictions.
Data Privacy Frameworks participation	We comply with the EU-U.S. and Swiss-U.S. Data Privacy Frameworks, and UK Extension to EU-U.S. DPF, as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of EEA, UK and Swiss App Data (as defined below) transferred from the EEA, UK and Switzerland to the United States.
Third party activities	If you view third-party websites or use third-party applications or services while using the App, then this Privacy Policy will not apply to information collected by that third party's website, application, or service.
Changes to this privacy policy	If we make any material changes to this Privacy Policy we will notify you by contacting you through our services, via email, through prominent notice in our Apps, or by posting a prominent notice on our website.
Contacting us	If you have any questions or comments about this Policy or our privacy practices, please contact us at support@seven.com.

 

Full Privacy Policy

We collect, use, share or otherwise process your personal information, as described in further detail below, when we have an appropriate basis for doing so. For example, we may process your personal information as necessary to provide services, such as the App, that are subject to terms you have accepted, such as our end user license agreements or Terms of Use. We may process your personal information for purposes of pursuing our legitimate interests, if doing so is consistent with your rights and appropriate to the context, such as to provide and improve our products and services; to communicate with you; to perform business analysis and research; to provide analytics services; to prevent fraud; to enforce legal claims, our policies, and terms; in connection with a transfer of assets; and for security purposes. We may also process your personal information to comply with legal obligations or when we obtain your consent to do so.

What information does SEVEN collect?

Information You Provide

You may provide us with certain personal information when you use the App. For example, we may collect your email address when you request support through the App. Additionally, if you otherwise contact us, we may keep a record of your communication, contact information, and other information you provide to us.

Information We Collect Automatically

When you use the App, you choose to route some or all of your device's data traffic through, or to, the App. The App processes this information on your device in order to provide ad-blocking services. For example, the App will analyze outgoing data and, when it identifies requests to retrieve ads, the App will block the request. The App will also analyze information your device transmits to facilitate ad-blocking services. Generally, the data transmitted through or to the App resides on your device, and we do not collect it and store in on our servers. However, we may automatically collect some information routed through the App, such as the following:

• Information about your device, including device identifiers, such as our App identifier and Google Analytics for Firebase identifier associated with your device, the type of device and its operating system, the mobile carrier or network, IP address, battery information, and general location information (based on cell tower data).
• Information about your mobile applications and data usage, including the applications installed on your device, your use of those applications, webpage addresses (URLs), and the amount of data you use.
• The battery and network performance of your device, including signal quality readings and information on failed calls.

How does SEVEN use the collected information?

We may use the information we collect, including personal information, to provide products and services and to support our business functions. For example, we may use this information to:

• Provide the App and its services to you.
• Communicate with you, including to respond when you communicate with us, send you information you request, or provide information on App updates.
• Perform business and data analysis and research, including analysis of how users use applications and data in order to maintain, improve, troubleshoot, and administer our App; provide customer support to our users; perform internal recordkeeping.
• Enforce our Terms of Use; prevent unlawful activities and misuse of the App; protect the legal rights, property, safety, and security of SEVEN, our Affiliates, our users, and others; and resolve disputes.
• Comply with applicable laws and industry standards.

We retain personal information for as long as we reasonably need it to fulfill the purposes described in this Policy, comply with our legal obligations and policies, resolve disputes, and enforce our agreements.

How does SEVEN share the collected information?

We may share personal information (as well as non-personal information) in the following instances:

• Affiliates. We may share information with our Affiliates (as defined above) to help provide services and improve our App (such as by providing analytics).
• Service Providers. We may share information with third parties that perform services on our behalf. For example, we may use third parties to host our services and databases, perform analyses or research, or send communications on our behalf.
• When Required by Law, to Respond to Legal Process, to Prevent Fraud, etc. We may share information to comply with a legal obligation; when we believe in good faith that the law requires it; at the request of governmental authorities; to respond to a legal request or legal process; to detect, prevent, or address fraud and other illegal activity; to protect the rights, property, safety, or security of ourselves, our Affiliates, you, or others, including as part of investigations; to enforce or verify compliance with our policies; to enforce our rights; to respond to an emergency; if we believe that you have abused your rights to use the App or violated an applicable law; or in connection with any dispute between you and us with respect to the App.
• In Connection with a Transfer of Assets. If we sell all or part of our business, make a sale or transfer of assets, are otherwise involved in an actual or potential merger or business transfer, or in the event of bankruptcy, we may disclose and transfer information to one or more third parties in connection with that transaction, proposed transaction, or bankruptcy proceeding. We also may disclose information to our attorneys and consultants.
• Other Disclosures. We also may share information as described to you at the point of collection or pursuant to your consent.

Your Choices

You may choose not to provide the personal information we request. However, not providing information we request may restrict your ability to use certain App features. For example, you may be able to restrict the collection of personal information or functionality through your device's operating system, but doing so may prevent you from using the functionality of the App.

You may be able to control many tracking tools, including cookies, from your browser. In particular, you may refuse to accept browser cookies by activating the appropriate setting on your browser. However, this browser setting may not apply to your use of the App. If you do not wish for the App to collect information about you in accordance with this Privacy Policy you should refrain from using the App and delete the App from your device. For example, to opt out of future collection of information we use in connection with Google Analytics for Firebase features we have implemented, described above, you must stop using and uninstall the App..

Some Internet browsers have a 'do not track' feature that lets you tell websites that you do not want to have your online activities tracked. The App does not respond to do-not-track signals.

If you stop using the App, you can request that we remove the personal information that we collected from you through the App by contacting us at support@seven.com. Users of the App may review or modify their personal information collected and stored by SEVEN through their use of the App by contacting us at support@seven.com. If you are located in the European Economic Area ("EEA"), UK, or Switzerland, then you may have the right to request access to, correction of, erasure of, or the transfer of your personal information, as well as the right to object to or restrict the processing of your personal information. You can exercise these rights, if applicable, by contacting us at support@seven.com. We may not be able to accommodate all requests, such as when we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Security

We maintain safeguards to help protect against loss, misuse, unauthorized access, disclosure, alteration, or destruction of the information we receive.

International Data Transfers

We may store and process information in the United States, the EEA, UK, Switzerland and other jurisdictions, which may result in the transfer of personal information from your device to a jurisdiction with different data protection laws than the jurisdiction in which you are located or reside. We will treat your personal information as subject to, and protect it in accordance with, this Policy regardless of the jurisdiction to which it is transferred.

With respect to personal information collected by SEVEN from individuals located in EEA member countries, UK and Switzerland through the App (“EEA, UK and Swiss App Data”), we comply with the EU-U.S. and Swiss-U.S. Data Privacy Frameworks, and UK Extension to the EU-U.S. DPF, as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of EEA, UK and Swiss App Data transferred from the EEA, UK and Switzerland to the United States. We are committed to subjecting all EEA, UK and Swiss App Data to the Data Privacy Framework Principles. We have certified to the U.S. Department of Commerce that we adhere to the Data Privacy Framework Principles with respect to EEA, UK and Swiss App Data. If there is any conflict between the terms in this Policy and the Data Privacy Framework Principles, the Data Privacy Framework Principles shall govern. To learn more about the Data Privacy Framework program, and to view our certification, please visit www.dataprivacyframework.gov.

We comply with the Data Privacy Framework Principles for onward transfers of EEA, UK and Swiss App Data including the onward transfer liability provisions. Under the Data Privacy Frameworks, we are responsible for the processing of EEA, UK and Swiss App Data we receive under the Data Privacy Frameworks and subsequently transfer to a third party acting on our behalf, unless we establish that we are not responsible for an event giving rise to damage. The U.S. Federal Trade Commission has jurisdiction over SEVEN’s compliance with the Data Privacy Frameworks. We commit to resolve complaints about our collection or use of your EEA, UK and Swiss App Data transferred to the United States pursuant to the Data Privacy Frameworks. If you desire to request access to your EEA, UK and Swiss App Data, or if you have other inquiries or complaints regarding our Policy or practices, you should first contact us at support@seven.com. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, you may contact JAMS Mediation, Arbitration and ADR Services (“JAMS”), an alternative dispute resolution provider based in the United States, free of charge, at www.jamsadr.com/DPF-Dispute-Resolution. Under certain conditions, you may invoke binding arbitration for complaints regarding Data Privacy Framework compliance that are not resolved by any of the other Data Privacy Framework mechanisms. Additional information on the binding arbitration process can be found on the Data Privacy Framework website: www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf.

Links to Other Websites and Services; Third-Party Content and Data Collection

Third party websites, applications, and other services accessed while you are using the App are not under the control of SEVEN and SEVEN shall have no responsibility or liability for the content or privacy practices of any such websites, applications, or other services or any link at any time. If you view third-party websites or use third-party applications or services while using the App, then this Privacy Policy will not apply to information collected by that third party's website, application, or service, and you must read the privacy policy associated with that website, application, or service to determine how your information will be collected, used, and disclosed. We do not allow third parties to use the App to collect personal information about your online activities over time and across different websites, applications, and other online products or services. However, websites, applications, and other online products or services that transmit traffic through the App may engage in such collection or permit other parties to do so. For example, a website that you access may collect personal information about your web browsing history across multiple websites over time or allow another party to do so.

Changes to this Privacy Policy

We may update this Policy to reflect changes in our privacy practices at any time and without prior notice to you. If we make any material changes, we may notify you by contacting you through our services, emailing you (to the address specified in your account, if we have an address for you), or by posting a notice on the App or our website-or by some combination of these methods. We encourage you to periodically review this Policy for the latest information on our privacy practices.

If you do not agree to any modifications to this Policy, your sole recourse is to immediately stop all use of the App. Your continued use of the App following the posting of any modifications to this Policy will constitute your acceptance of the revised Policy.

Contacting Us/Reporting Violations

If you have any questions or comments about this Policy or our privacy practices, or to report any violations of the Policy or abuse of the App, please contact us at support@seven.com. Individuals located in the EEA, UK or Switzerland also have the right to lodge a complaint with an EEA, UK or Swiss supervisory authority, as applicable.

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