Privacy Policy

1. Introduction and Company Information

Recomob (hereinafter referred to as "Recomob," "we," "us," or "our") refers to RECOMOB PTE. LTD., a company registered and operating in Singapore.

We are committed to protecting personal data and respecting privacy in accordance with applicable data protection laws and internationally recognized standards.

This Privacy Policy explains how we collect, use, disclose, and safeguard information when providing our digital advertising and marketing services, including but not limited to:

• Mobile Growth: Mobile app user acquisition, attribution, and in-app performance optimization
• Lead Generation: Compliant B2B and B2C lead generation services
• Paid Media: Google Ads management and programmatic advertising campaigns

2. Our Commitment to Privacy

We recognize privacy as a fundamental right and commit to the following principles:

• Transparency – Clear disclosure of data practices
• Data Minimization – Collecting only what is necessary
• Security – Applying appropriate technical and organizational safeguards
• Compliance – Adhering to applicable global data protection laws
• User Control – Respecting individual rights and choices
• Accountability – Taking responsibility for data processed on behalf of clients

3. Scope of This Policy

This Privacy Policy applies to personal information processed through:

• Our corporate website (recomob.com)
• Advertising campaigns and marketing services operated by Recomob
• Lead generation forms, landing pages, and validation processes
• Email, telephone, and other electronic communications
• Third-party platforms where we operate campaigns
• Any future proprietary platforms, technologies, or software products developed and operated by Recomob, unless otherwise stated

4. Roles Under Data Protection Law

Depending on the specific service provided, Recomob may act as:

• Data Processor – when processing end-user data on behalf of advertising clients (e.g., Mobile Growth and Paid Media services)
• Data Controller – when processing business client data, operating our website, and managing direct relationships
• Joint Controller – in certain Lead Generation campaigns, depending on campaign structure and contractual arrangements

Appropriate contractual safeguards are implemented to define responsibilities in accordance with applicable laws.

5. Information We Collect

5.1 Business Client Information

• Name, business email, phone number, job title
• Company name, address, industry, size
• Account credentials and authentication data
• Billing and payment information
• Campaign objectives, KPIs, and communications

5.2 End-User Advertising Data (Mobile Growth & Paid Media)

Processed on behalf of clients as a Data Processor:

• Device information (type, OS, language)
• Advertising identifiers (IDFA, GAID), IP address
• Approximate location (subject to consent)
• App interaction and attribution data
• Ad impressions, clicks, conversions
• Network and carrier information

5.3 Lead Generation Data

Collected with explicit consent:

• Name, email, phone number
• Company and job-related information
• Industry, interests, budget range (if applicable)
• Consent and opt-in records

Lead data is shared with clients only for agreed purposes and in compliance with applicable laws.

5.4 Automatically Collected Information

• Browser and device information
• Referring URLs and page interactions
• Cookies and similar technologies
• Server logs and diagnostics

For details, please refer to our Cookie Policy.

5.5 Third-Party Sources

We may receive information from attribution providers, advertising platforms, and trusted partners to support campaign execution and measurement.

6. How We Use Your Information

6.1 Service Delivery

• Campaign execution, attribution, and optimization
• Lead capture, validation, and delivery
• Performance measurement and reporting

6.2 Business Operations

• Billing and transaction management
• Customer support
• Service improvement and analytics

6.3 Compliance and Security

• Fraud detection and prevention
• Legal compliance
• Enforcement of policies and agreements

6.4 Marketing Communications (With Consent)

• Service updates and promotional content
• Industry insights and events

7. Legal Basis for Processing (GDPR)

For EEA, UK, and Swiss users, processing is based on:

• Consent
• Contract performance
• Legal obligation
• Legitimate interests (balanced against user rights)

8. Automated Decision-Making and Profiling

Recomob may engage in data-driven optimization and profiling for advertising and performance measurement purposes.

We do not conduct automated decision-making that produces legal or similarly significant effects on individuals without appropriate safeguards, human oversight, and consent where required by law.

9. Information Sharing and Disclosure

9.1 Clients and Partners

• Lead data shared only with consent
• Aggregated or performance data shared for reporting

9.2 Service Providers

Third parties assisting with hosting, analytics, payments, advertising delivery, and CRM are bound by contractual confidentiality and data protection obligations.

9.3 Legal Obligations

Disclosure may occur where required by law or necessary to protect rights, safety, or security.

9.4 Business Transfers

Data may be transferred in corporate transactions, subject to applicable safeguards.

9.5 Aggregated and Anonymized Data

Used for research, benchmarking, and service improvement.

10. Data Retention

• Business client data: duration of relationship + 7 years
• Mobile advertising data: up to 90 days, then aggregated or deleted
• Lead generation data: until deletion request or 2 years of inactivity
• Marketing data: until opt-out
• Website analytics: up to 26 months

Where Recomob acts as a Data Processor, retention follows client instructions, subject to legal requirements.

11. Your Privacy Rights

11.1 Rights

• Access, correction, deletion
• Objection and restriction
• Data portability
• Withdrawal of consent

11.2 Requests

Email: contact@recomob.com

Subject: Privacy Rights Request

Response time: up to 30 days

11.3 Opt-Out

• Email marketing: unsubscribe link
• Mobile ads: device-level controls
• Cookies: browser or consent manager

12. International Data Transfers

Data may be processed in Singapore and other jurisdictions using safeguards such as:

• Standard Contractual Clauses (SCCs)
• Adequacy decisions
• Data processing agreements
• APEC CBPR framework

13. Security Measures

Encryption, access controls, audits, monitoring, and incident response procedures are implemented.

In the event of a personal data breach, notifications will be made where required by applicable law, without undue delay.

14. Regional Privacy Laws

GDPR / UK GDPR

Full compliance with European data protection regulations.

CCPA / CPRA

• We do not sell personal information
• Where data may be considered "shared" under CPRA, users may opt out

PDPA (Singapore)

Compliance with Singapore's Personal Data Protection Act.

Other jurisdictions: LGPD, PIPEDA, APPI, Australian Privacy Act

15. Children's Privacy

• Our services are not directed at individuals under 16 (or applicable age).
• We comply with COPPA and do not knowingly process children's data without required safeguards.

16. Third-Party Links

We are not responsible for third-party privacy practices. Please review their policies separately.

17. Updates to This Policy

Updates will be reflected by the "Last Updated" date and, where required, communicated to users.

18. Contact Us