Ooooh boy, privacy! – Performance Tracker

You must have ended up here because you care about your and your users’ privacy. That’s great.

The lawyers make us write a bunch of fancy words in our official policy but its worth laying out in more plain language what our policy on data privacy is.

There are two different kinds of data we touch: your personal data as the developer and the data of your customers who use your app that uses RevenueCat. We have different policies for each and it’s worth breaking down:

Your Personal Data

For your personal data as a developer, we act in the role of a “controller” and in our privacy policy we lay out a fairly standard set of policies. We aren’t interested in selling your personal data but we may use it to send you emails, track you with our own analytics tools etc. This is all so that we can improve RevenueCat.

Your Revenue and Customer Data

Your customer data, which would, by association, include information about your business, are under a completely different set of policies. In GDPR terms, we are a “processor” here. This data is probably why you are here in the first place. Two important points:

We will never share information about your app outside of RevenueCat

The data about your revenue and your users stays within RevenueCat. We do utilize some 3rd party services for hosting, such as AWS, but that data is encrypted and unavailable to those providers.

We will never send identifiable information about your users to 3rd parties without your consent

With the exception of opt-in integrations, we won’t send information about your subscribers to any 3rd parties. We don’t want the liability of any downstream processors having issues and compromising your data. We want to keep it with us, where we can have some control over its security.

We will never sell your data

We’re in the business of making money off of you making money. We have no interest in trying to turn a 2nd order profit by fencing information about your business. We may, at some point, utilize aggregate data to provide insights in our app (i.e. “your app is 20% below average for churn”), but it would not be possible to extract any meaningful information about your business from that.

The data you send us is governed by your privacy policy

The user data you send to us should be disclosed in your own privacy policy. If you use a custom App User ID or send us attribution information, that may contain personal information. See our data processor addendum and be sure to disclose such sharing to your customers in your own privacy policy.

RevenueCat Privacy Policy

Last update: January 24th, 2019

This is the Privacy Policy for the website hosted at https://www.revenuecat.com/ (“our site”), and for other RevenueCat activities at which you may provide your personal data, such as sponsored events or trade shows. The site is operated by or on behalf of RevenueCat, Inc. (“we”,”us”). We are committed to protecting and respecting your privacy.

This policy (together with our terms of service and any other documents referred to in it) sets out:

Information we collect about you
Cookies and other technologies
How we use your information
Our promotional updates and communications
Who we give your information to
Where we store your information
How we protect your information
How long we keep your information
Your rights
Changes to this policy
Contact us

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By engaging in our site and services, you acknowledge you have read and understood this privacy policy. For the purposes of Applicable Data Protection Laws including the European Economic Area data protection law, (the “Data Protection Law”), the data controller is: RevenueCat, Inc., 633 Taraval St. Suite 101, San Francisco, CA, 94116

Our site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.

Information we collect about you

We will collect and process the following personal data from you:

Information you give us
This is information about you that you give us by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, subscribe to our service, search for a product, in discussion boards or other social media functions on or via our site, enter a competition, promotion or survey, submit a query, providing information at trade shows or sponsored events and when you report a problem with our site.
The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph, login and password details.
It may also include employment details if you send us a CV, resumé or other details of your employment history in connection with an advertised job vacancy or a general inquiry regarding employment opportunities with us.

Information we collect about you from your use of our site

Technical information
Technical information may include the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, operating system and platform;
Information about your visit
Information about your visit may include the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our customer service team.
IP Location data
Location data – IP addresses are collected and location is inferred based on IP location.
Information collected from platform activities
With respect to our Services, we collect information under the direction of our Customers (the data controller), and have no direct relationship with the individuals whose personal information it processes. The processing of data sent from our Customers is governed by our Terms of Use, Data Processing Addendum or any other agreement agreed to and signed by us with our Customers. If you are a customer of one of our Customers and would like more information on their use of your data, please contact the Customer that you interact with directly. We acknowledge that you have the right to access your personal information. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his or her query to the RevenueCat Customer (the data controller) who will then provide instructions to us, if necessary. If requested to remove data we will respond within a reasonable timeframe. We will retain personal information pursuant to our retention policy and will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Information we receive from other sources

This is information we receive about you:

If you use any of the other websites or apps we operate or the other services we provide.
From third parties we work with.
In this case we will have informed you when we collected that data and if we intend to share your data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, and search information providers).

Cookies and other technologies

Our site uses cookies and/or other similar technologies such as device-IDs, in-app codes, pixel tags or web beacons to collect and store certain information. These typically involve pieces of information or code that a website transfers to or accesses from your computer hard drive or mobile device to store and sometimes track information about you. Cookies and similar technologies enable you to be remembered when using that computer or device to interact with websites and online services and can be used to manage a range of features and content as well as storing searches and presenting personalized content. Our site uses cookies and similar technologies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and use our service and also allows us to improve our site. Most web browsers automatically accept cookies and similar technologies, but if you prefer, you can change your browser to prevent that and your help screen or manual will tell you how to do this. However, you may not be able to take full advantage of our website if you do so. A number of cookies and similar technologies we use last only for the duration of your web or app session and expire when you close your browser. Others are used to remember you when you return to the site and will last for longer. We use these cookies and other technologies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that these are not overridden by your rights), and, in some cases, where required by law, where you have consented to their use.

How we use your information

Information you give to us:
We will use this information in our legitimate interests, where we have considered these are not overridden by your rights:
To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
To keep our site safe and secure.
For measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
To improve our site to ensure that content is presented in the most effective manner for you and for your computer.
To allow you to participate in interactive features of our service, when you choose to do so.
Information we receive from other sources
We may combine this information with information you give to us and information we collect about you in our legitimate interests (where we have considered that these are not overridden by your rights). We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Our promotional updates and communications

Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal information for marketing analysis and to provide you with promotional update communications by email about our products and services. You can object to further marketing at any time by checking and updating your contact details within your account, or selecting the “unsubscribe” link at the end of all our marketing and promotional update communications to you, or by submitting your email address here.

Who we give your information to

We may give your information to:

Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, who support our processing of personal data under this policy. If any of these parties are using your information for direct marketing purposes, we will only transfer the information to them for that purpose with your prior consent.
Selected third parties may include:
Organizations who process your personal data on our behalf and in accordance with our instructions and applicable law. This includes organizations supporting the services we offer through the site, in particular organizations providing website and data hosting services, providing fulfillment services, distributing any communications we send, supporting or updating marketing lists, and facilitating feedback on our services. These organizations (which may include third party suppliers, agents, sub-contractors and/or other companies in the RevenueCat group of companies) will only use your information to the extent necessary to perform their support functions.
Analytics and search engine providers that assist us in the improvement and optimization of our site and subject to the cookie section of this policy (this will not identify you as an individual).
Payment processing providers who provide secure payment processing services. (Your payment card details are not shared with us by the provider.)
We will disclose your personal information to third parties:
In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets, subject to the terms of this Privacy Policy.
If RevenueCat or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of service, terms of use, and other agreements with you; or to protect the rights, property, or safety of RevenueCat, our customers, or others.

Where we store your information

The data that we collect from you will be stored securely on Amazon Web Services (“AWS”) in the USA.

Public forums

The site may, from time to time, make chat rooms, message boards, news groups and/or other public forums available to its users. Any information that is disclosed in these areas becomes public information and you should exercise caution when using these and avoid posting any personal information

Child safety

The site is intended for use only by persons who are at least 16 years of age. By using the site, you confirm to us that you meet this requirement. If you are under the age of 18, you confirm you have received permission from your parent or guardian before using this site or sending us personal information.

Payment processing

Payment details you provide will be encrypted using secure sockets layer (SSL) technology before they are submitted to us over the internet. Payments made on the site are made through our payment gateway provider. You will be providing credit or debit card information directly to the operator which operates a secure server to process payment details, encrypting your credit/debit card information and authorizing payment. Information which you supply is not within our control and is subject to the operator’s own privacy policy and terms and conditions.

How we protect your information

Security is one of our biggest priorities at RevenueCat. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

All application data is secured in transit using TLS.
Any payment transactions will be encrypted using SSL.
RevenueCat audits changes to the application throughout the development lifecycle: architecture reviews are performed as well as stringent automated and manual code review processes.
RevenueCat monitors application servers, infrastructure, and the RevenueCat network environment to detect potential abuse.
RevenueCat uses Amazon Web Services (“AWS”) to persistently store Customer data and does not host Customer data on its premises. AWS is a leading cloud provider, and holds industry best security certifications, such as SOC2 and ISO 27001. Customer data sent to RevenueCat from around the world is sent to AWS data centers located in the United States.

How long we keep your information

We retain personal data during any period in which you have expressed an interest in our products and services, for as long as you have an account with us in order to meet our contractual obligations to you, and for six years after that to identify any issues and resolve any legal proceedings. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

EU Citizen rights under GDPR

You have the right under certain circumstances:
to be provided with a copy of your personal data held by us.
to request the rectification or erasure of your personal data held by us.
to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example).
to object to the further processing of your personal data, including the right to object to marketing.
to request that your provided personal data be moved to a third party.
You may opt out at any time from allowing further access by us to your location data by emailing compliance@revenuecat.com.
Your right to withdraw consent:
Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by going here.

You can also exercise the rights listed above at any time by contacting us at compliance@revenuecat.com.

We would appreciate the opportunity to directly address any GDPR issues you may have. Please contact us at compliance@revenuecat.com. You do, however, have the right to approach your local data protection authority, (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html for data protection authorities in the EU).

Data processed on behalf of our Customers

RevenueCat may process personal data on behalf of its customers. We are not the controllers of this data and act as data processors. We will process such data on behalf of the customer as prescribed in the respective agreements between RevenueCat and the customer. The customer’s privacy policy or other agreement between the customer and you (or your organization) will apply to such processing, and not this policy. If your personal data is processed by RevenueCat on behalf of one of our customers and you wish to discontinue such processing, please contact the RevenueCat customer directly. To exercise any of your rights as a data subject, please contact the RevenueCat customer directly.

Customer agreements are in place with each RevenueCat customer. These agreements cover data transfers to third parties that may occur as part of RevenueCat’s provision of its services to the customer.

Changes to this policy

Any changes we make to our privacy policy in future will be posted on this page and, in relation to substantive changes, will be notified to you by e-mail. This policy was last updated on July 31st, 2019.

Contact Us

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to:

Ralf Bönisch
Kleiner Ring 15a
49078 Osnabrück
Germany