Privacy Notice "Competitor Assessment" Solution

Last updated: November 2023

1. General - the "Competitor Assessment" Solution

rankcusp processes your Personal Data (as defined below) in order to provide its own customers with the "Competitor Assessment" Solution (the "Service").

To provide this Service, a questionnaire (the "Questionnaire") is sent to you electronically at the request of rankcusp customers who wish to assess their own competitor lists, so that your app listing can be included in an ASO report.

Based on the answers you give (or do not give) in the Questionnaire, rankcusp may give you a "score" ranging from A+ to E, which indicates the maturity of the ASO strategy you run as an app owner.

Depending on the score you receive, rankcusp may also process your personal data for direct marketing purposes, in order to suggest that you subscribe to the rankcusp platform and so get the chance to improve your own ASO report.

2. General - this Privacy Notice

As data controller, rankcusp ("rankcusp" or "we") undertakes to protect your privacy and the confidentiality and security of the personal data it processes, in accordance with the applicable data protection legislation and with European Regulation 2016/679 of 27 April 2016 (the "General Data Protection Regulation" or "GDPR").

Personal data means any information that can identify you directly (your name, for instance) or indirectly (your telephone number, for instance) ("Personal Data").

This privacy notice (the "Privacy Notice") explains how we process your Personal Data as part of the Service. We therefore ask you to read it carefully.

3. Where does your Personal Data come from?

We process only the Personal Data you give us directly when answering the questions in the Questionnaire sent to you, at our customers' request, for the purpose of providing the Service.

4. How your Personal Data is processed

PURPOSE OF PROCESSING	PERSONAL DATA COLLECTED	LEGAL BASIS	RETENTION PERIOD*
Verifying the accuracy of the information given in the Questionnaire	Professional data (role, company name) together with identity and contact data (surname, first name, business email address)	rankcusp's legitimate interest	3 years from collection or from the last contact with you
Direct marketing by telephone	Identity and contact data (surname, first name, business telephone number), language or languages spoken	rankcusp's legitimate interest	3 years from (i) the last contact with you or (ii) the end of our contractual relationship, if you have subscribed to the rankcusp platform

*At the end of these retention periods, the Personal Data of yours that is strictly necessary may be archived in an intermediate database for administrative reasons (legal, accounting, tax and so on). For example, it may be archived for 5 years from the end of the retention period in the active database for litigation purposes (for the length of the limitation period), and for 10 years for accounting purposes. At the end of those periods the data is deleted from our databases.

5. Do we share your Personal Data?

To provide the Service, rankcusp may share your Personal Data with the following recipients:

Trusted service providers	Categories of trusted service provider: • To host your Personal Data in our databases for the retention periods described above: your Personal Data is shared with our hosting provider, established within the European Union; • To make first contact with you: your Personal Data may be shared with our email infrastructure provider, which hosts data solely within the European Union; • To manage the commercial relationship with you: your Personal Data may be shared with our customer relations provider, which hosts data solely within the European Union. rankcusp makes sure these third parties apply security measures that guarantee the confidentiality, integrity and availability of your Personal Data.
rankcusp internal departments	Your Personal Data is processed by rankcusp's authorised internal departments
Administrative and judicial authorities	rankcusp may have to disclose your Personal Data when requested by judicial and administrative authorities with a legitimate interest in accessing it, or in order to defend its own rights before the competent authorities. In addition, if rankcusp is the subject of a transfer of business or assets, we may pass your Personal Data on to the prospective buyer of that business or those assets

6. Do we transfer your Personal Data outside the European Economic Area (EEA)?

The Personal Data we process is hosted solely within the European Union.

Should we need to transfer any of your Personal Data to a recipient located outside the EEA, we will ensure, as the case may be, that (i) the service provider is located in a country covered by an adequacy decision of the European Commission or (ii), where that is not possible, that rankcusp applies the appropriate safeguards under the GDPR (standard contractual clauses adopted by the European Commission) together with additional technical and organisational security measures

7. What rights do you have over your Personal Data, and how do you exercise them?

As a data subject you have the following rights:

· right of access: the right to be told which Personal Data we process about you, for what purposes and for how long, and to obtain a copy of your Personal Data in an intelligible form (you may be asked to prove your identity in case of reasonable doubt);

· right to rectification: the right to ask that inaccurate or incomplete Personal Data be corrected, completed and/or updated;

· right to restriction: the right to ask us to restrict one or more processing operations on your Personal Data in the specific cases listed in Article 18 of the GDPR (for instance while rankcusp is considering your objection request);

· right not to be subject to certain decisions: under Article 22 of the GDPR you may ask not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you;

· right to object: the right to object to the processing of your Personal Data on grounds relating to your particular situation (under the conditions set out in Article 21 of the GDPR). Where your Personal Data is processed for direct marketing purposes, you may object to that processing at any time, including profiling (to the extent it is linked to such direct marketing);

· right to erasure (the "right to be forgotten"): the right to ask for your Personal Data to be erased in the specific circumstances set out in Article 17 of the GDPR. In certain cases, however, we may have to retain your Personal Data (for instance to meet a legal obligation that requires the Personal Data to be processed);

· right to portability: where your Personal Data is processed on the basis of your consent or because it is necessary for the performance of a contract, the right to receive it in a structured, commonly used, machine-readable format and to ask us to transmit it to another controller;

· rights after death: under the applicable legislation you have the right to ask us to set instructions on the storage, erasure and communication of your Personal Data after your death; and

· the right to lodge a complaint with a supervisory authority, in particular in the country where you live or work (if relevant) or where the alleged infringement took place. If you bring your request to us first, we will do our best to resolve the matter quickly

To exercise your rights, contact us directly:

· by email: oguzhancart1@gmail.com; oguzhancart1@gmail.com

· by post: writing to the rankcusp Data Protection Officer, at the postal address given on the site.

8. Changes to this Privacy Notice

rankcusp may amend this Privacy Notice from time to time in order to keep it up to date. You can tell when it was last changed from the "Last updated" line at the top of the text.

Whenever we plan substantial changes to this Privacy Notice (a change in the purposes for which Personal Data is processed, for instance), we will inform you before those changes take effect.