Privacy Policy
Last updated: August 4, 2026
Our Privacy Policy contains the following sections:
- Introduction
- Data protection officer (DPO)
- Article 1 – How AppTweak processes personal data
- Article 2 – What data do we collect, from which categories of Data Subjects, and for which purposes?
- Article 3 – What is the legal basis for the processing of your personal data?
- Article 4 – How long will we keep your data?
- Article 5 – Will we use data for direct communication and marketing purposes?
- Article 6 – What are your rights?
- Article 7 – What security measures do we take?
- Article 8 – Do we disclose your data to third parties?
- Article 9 – Will we transfer data to a country outside of the European Economic Area?
- Article 10 – Updates and changes to the policy
- Article 11 – Validity of the contractual clauses
- Article 12 – Applicable law and jurisdiction
Introduction
AppTweak SA (hereafter: we, us or AppTweak) may collect and process personal data and, within this framework, is committed to protecting your personal data and respecting your privacy in accordance with Data Protection Laws and under the conditions detailed hereunder.
This Privacy Policy is applicable to the processing of personal data carried out by the Data Controller identified as AppTweak SA, with its registered office at 1050 Brussels (Belgium), Avenue Louise 235, registered with the Crossroads Bank for Enterprises under the VAT number BE0839.873.510.
This Privacy Policy applies, among other things, to:
- our general and informative website (https://www.apptweak.com), hereafter: the “General Website” and the SaaS Platform (https://app.apptweak.com), hereafter: the “Solution” (all together hereinafter: the “Site”), its subdomains, and related services;
- all existing (commercial) relations between AppTweak and its customers, prospects and business partners; and
- anyone with whom we may have a relationship.
With regard to the Site, the Privacy Policy applies to all pages hosted on the Site and registrations relating to this Site. It does not apply to pages hosted by third parties, to which AppTweak may refer and whose privacy policies may differ. AppTweak cannot, therefore, be held responsible for any data processed on these websites or by them.
People under the age of 18 and people who do not have full legal capacity are not allowed to use the Site. AppTweak asks them not to provide their personal data. Any infringement found in this provision must be reported without delay to the following address: dpo(Replace this parenthesis with the @ sign)apptweak.com.
AppTweak wishes to underline that it makes every effort to act at all times in compliance with Data Protection Laws, meaning all European Privacy Laws, where applicable, (i) EU Regulation 2016/679, adopted on 27 April 2016 (“GDPR”), (ii) Directive 2002/58/EC of 12 July 2002 (“e-Privacy Directive”), and any legislation replacing the GDPR and the ePrivacy Directive, (iii) any law, statute or regulation relating to the protection of personal data of a Member State of the European Economic Area (“EEA”), which may apply to one of the Parties in the context of its data processing activities or its establishment in the EEA, and all subordinate legislation made under them, together with any codes of practice or other guidance issued by the data protection regulator in the Territory.
Please read this Privacy Policy carefully and in conjunction with AppTweak’s Services (/en/legal/terms-of-services) of the SaaS Platform, Terms of Use (/en/legal/terms-of-use) of the Website, and Cookies Policy. It contains essential information on how your personal data is processed. By accessing the Site, by sharing your personal data on our Site, by contacting us by email/phone/any other way, by submitting a question/complaint/file, you declare that you have read this Privacy Policy and expressly agree to its contents. When we contact you, we will communicate this Privacy Policy to you. By subsequently contacting us, you declare that you have read this Privacy Policy and expressly agree to its contents.
If you have any other questions, do not hesitate to contact us at the following address: dpo(Replace this parenthesis with the @ sign)apptweak.com.
Data Protection Officer (DPO)
Pursuant to Article 37 GDPR, AppTweak has appointed a Data Protection Officer (more commonly known as “DPO”) to act as a single point of contact within our organization. Our DPO has been appointed on the basis of her professional qualities and, in particular, her expert knowledge of data protection law and practice and her ability to carry out the tasks covered by the GDPR. Here are her full contact details:
- Charlotte De Raef
- +32494883623
- dpo(Replace this parenthesis with the @ sign)apptweak.com
Article 1 – How AppTweak Processes Personal data
AppTweak processes personal data in different capacities depending on the context in which the data is collected and used.
AppTweak as Controller
AppTweak acts as a Controller (determines the purposes and means of processing) in the following situations:
- (i) Direct interactions. When you create an account, subscribe to our services, request a demo, register for an event, visit our websites, or otherwise communicate with us.
- (ii) Business operations. When AppTweak collects and processes personal data for its own business purposes, including account administration, billing, security, fraud prevention, compliance, marketing and promotional communications, business development, analytics, and market intelligence.
- (iii) Workforce data. When processing personal data relating to job applicants, employees, contractors, and other members of its workforce for recruitment, human resources management and legal compliance purposes.
- (iv) App Store data aggregation and analysis. When collecting publicly available personal data from third-party app stores (Apple App Store and Google Play Store), in particular the content of app reviews, the ratings and the associated usernames. AppTweak processes this data on a continuous basis for its own purposes, including sentiment analysis and the production of aggregated statistics on published ratings.
AppTweak as Processor
AppTweak acts as a Processor when customers use the platform and services to collect and process personal data in connection with their business activities. In this case, AppTweak acts as a Processor on behalf of its customers, who are the Controllers of such personal data, in accordance with AppTweak’s Data Processing Agreement (DPA) incorporated into the applicable Subscriber Agreement.
Article 2 – What data do we collect, from which categories of Data Subjects, and for which purposes?
By registering or completing a form available on AppTweak’s Site or in paper format (for example, subscription to AppTweak’s newsletter, contact form, demo registration, downloadable content form, screening questions for applications), the Data Subject authorizes AppTweak to record and store the following information. The purposes of processing and corresponding types of data collected are detailed in the summary tables below for each category of Data Subject.
2.1. If the Data Subject is a job applicant
| Purpose of processing | Type of data |
|---|---|
| Recruitment of employees, interns, and staff members. Assessment of application. |
Identification data (name, email, phone, EU citizenship/visa, location). Photo (not mandatory). |
| Evaluation of candidacy and responding to applicant queries. Establishing and executing the contractual relationship. |
CV, cover letter, LinkedIn profile data (academic/professional experience, education, interests, linguistic competence). Academic and professional background data. |
| Compliance with labour laws. | Diploma (if hired). |
| Responding to information requests from applicants and authorities. | Communications (email or other). |
| Identity verification and enforcement of the Privacy Policy. | Any additional personal data requested by AppTweak for identification or compliance purposes. |
AppTweak obtains the above personal data directly from you or via our partners, such as recruiting services, temporary agencies, etc. If you do not provide us with such information, we will not be able to continue our recruitment process.
2.2. If the Data Subject is a User of the Sites (of the General Website and the Solution)
| Purpose of processing | Type of data |
|---|---|
| Processing and responding to information requests and questions via the online chat and the Contact Form or by any other means of communication. An online chat is available on the Sites and contact form on the Public Website. You also have the opportunity to contact us by telephone, e-mail, and post. | Identification data (name, email, phone, postal address) – for authenticated services. |
| Technical management, security, and statistical analysis. | IP address. |
| Statistical surveys and Site improvement. | Date/time of access, traffic data, the search engine and keywords used to find our Sites. |
| Personalising the User experience and analysing Site content. | Demographic attributes. |
| Enhancing technical management and Site navigation. | Pages consulted, browser type, Operating System. |
| Memorising user preferences. | Browsing preferences (via cookies). |
| Scheduling demonstrations; informing about publications, activities, and Site upgrades or new functionality. | Contact form data (name, email, message). |
| Sending newsletters to receive news and tips on App Store Optimization and product/feature releases provided by AppTweak (such as AppTweak’s monthly newsletter). | Newsletter subscription data (email). |
| As part of the various services we offer, we offer you the possibility of subscribing to AppTweak’s monthly newsletter ticking the checkbox you’ll find under the contact forms on the public website (downloadable content forms, contact forms, sign up form), in order to be kept informed of promotional offers and product/features releases, receive tips on ASO and be informed of our next webinars and events. | |
| Identity verification and enforcement of the Privacy Policy. | Any additional personal data requested by AppTweak for identification or compliance purposes. |
To improve site navigation and enhance technical management, cookies may be utilized on the Sites. So, for example, AppTweak will automatically record which parts of the Site you visit, which web browser you use, which Sites you were visiting when you received access to the Site, etc. We cannot identify you on the basis of this data, but it allows AppTweak to establish statistics concerning the use of the Site. You can find more information relating to “cookies” in our Cookie Policy.
2.3. When the User accesses and uses the Solution
| Purpose of processing | Type of data |
|---|---|
| Registration and management of User Account; starting a free trial – creation of an online account and choice of a Plan, by inserting personal data used to link the account to the User. AppTweak does not have access to the User’s bank details. | Account data (surname, first name, email, password, country, company data, billing address, tax ID). |
| Providing integrated platform features as requested by the User. | Data from integrated third-party applications. |
| Performance of services, processing transactions, and executing instructions requested by the User; personal data will be held for the duration required to provide the subscribed service(s). | Subscription history. |
| Responding to queries and providing support. | Voluntarily disclosed personal data (e.g. via contact procedure). |
| Sending invoices and collecting payments; once payments are collected, data is processed by the accounting department for good management purposes (billing records, surname, first name, billing address). | Billing data (name, billing address). |
| Generating automatic bug reports when Users are facing technical issues. | Technical/diagnostic data (e.g. error logs, device and session metadata). |
2.4. If the Data Subject is an Apple App Store or Google Play Store reviewer
| Purpose of processing | Type of data |
|---|---|
| Sentiment analysis and the production of aggregated statistics on published ratings. | Public username / display name. Star rating, review date, app name, app store region. The personal data processed in this context is limited to publicly available information. |
2.5. If the Data Subject is a guest blog author
| Purpose of processing | Type of data |
|---|---|
| Responding to information requests from Data Subjects. Establishing and executing the partnership agreement. Any other purpose expressly consented to. |
Identification data (first name, surname, email, phone, postal address, picture). LinkedIn profile link, job title and employer name. |
| Identity verification and enforcement of the Privacy Policy. | Any additional personal data requested by AppTweak for identification or compliance purposes. |
2.6. If your data has been collected by a third party
| Purpose of processing | Type of data |
|---|---|
| Fulfilment of the purposes of personal data processing conducted by the third party (whether or not jointly with AppTweak). | Any personal data collected by a third party and shared with or made accessible to AppTweak. |
| Reporting and statistical analysis. | Aggregated or identifiable data provided by third parties. |
AppTweak may receive personal data from third parties such as business partners, recruiting services, temporary agencies, or other data controllers. The categories of personal data received depend on the third party and the purpose of the transfer, and may include identification data, contact details, and professional information.
Article 3 – What is the legal basis for the processing of your personal data?
The legal basis of the processing of your personal data is based on:
3.1. Your consent
If the legal basis of our treatment is your consent, you have the right to withdraw it at any time without prejudice to the lawfulness of the processing performed prior to withdrawal.
When you receive information in the context of direct communications, this means that you can unsubscribe at any time from newsletters and other commercial communications from us (e.g. invitations to training, events or webinars). You will be put in “opt-out”. You can unsubscribe by sending us an email at the following address: info(Replace this parenthesis with the @ sign)apptweak.com or by clicking on the “Unsubscribe” button at the bottom of all direct communications. Please note that it may take up to 5 working days to process your opt-out request.
3.2. The performance of a contract and the execution of any of your requests
We do need to collect some of your data to answer any request from you. If you choose not to share this data with us, it may render the performance of the contract impossible.
3.3. A legal obligation
We do need to collect and store some of your data to meet various legal requirements, including tax and accounting.
3.4. The protection of vital interests
3.5. The performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
3.6. Our legitimate interest, provided that it is in accordance with your interests, freedoms and fundamental rights.
We have a legitimate interest in providing you with this information and interacting with you, especially to respond to your requests or improve our services, prevent abuse and fraud, control the regularity of our operations, exercise, defend and preserve our rights, for example in litigation, as well as evidence of a possible violation of our rights, manage and improve our relations with you, continually improve our Site and our products/services unless such interests are supplanted by your interests or your fundamental rights and freedoms requiring the protection of your personal data.
Article 4 – How long will we keep your data?
4.1. AppTweak will keep the personal data of its Data Subjects for the duration necessary to achieve the objectives pursued (see Article 2), except where a longer retention period is required or justified (i) by law, namely in tax matters, or (ii) by compliance with another legal obligation.
AppTweak may also continue to keep personal data concerning the Data Subjects, including all correspondence or requests for assistance sent to us in order to be in a position to reply to all questions or complaints that may be sent to it or after an event organized by AppTweak.
4.2. Without prejudice to the exercise of your rights, the protection of our rights, and other storage obligations prescribed by law:
a) for job applicants’ data, your data will generally be kept for a maximum of 24 months after unsuccessful candidates are notified, with regard to the data detailed in Article 2.
b) for Successful Recruitment Candidate, your data will generally be kept longer. Information will be provided to you via the HR privacy policy.
c) for Public Website users’ data, your data will generally be kept for a maximum of:
- 24 months after the last contact for data communicated when contacting us (in the absence of an order);
- 24 months after your last visit to the Site.
d) for Solution users’ data, your data will generally be kept for a maximum of:
- 10 years after the deletion of your account/the placing of your last order, with regard to the following data:
- Data and information relating to the User when creating or using their User Account, such as the last name, first name, email address, password, country, and other data related to the company they work for and Client of AppTweak (such as the full legal name, email address, country, and optionally, the company name, billing address, and tax ID number);
- Subscription history;
- Data communicated when contacting us (except in the absence of performance of services by AppTweak – in this case, the data is kept for 24 months after the last contact).
e) for Apple App Store and Google Play Store reviewers’ data (public usernames, review text, and associated metadata), the data will be retained for as long as it remains necessary for AppTweak’s app store analytics services, and in any event for no longer than the review remains publicly available on the relevant app store.
f) for Guest blog authors’ data, your data will generally be kept as long as the blog is live and until it is removed from our website.
g) for the data retention period relating to cookies, you can find more information in our Cookie Policy.
4.3. Once this goal is achieved, we either delete or anonymize the personal data.
4.4. For more information on the retention periods applicable to your personal data, please contact AppTweak’s Data Protection Officer at dpo(Replace this parenthesis with the @ sign)apptweak.com.
Article 5 – Will we use data for direct communication and marketing purposes?
5.1. The personal data will not be used for direct communication purposes for articles or services that would not be identical or similar to those to which the User has already subscribed unless the User has previously explicitly consented to such use by ticking the boxes provided for this purpose (“opt-in”).
5.2. When you have given your consent to the use of this information for direct communication purposes, you retain the right to object to such use at any time, upon request, and free of charge. You may simply communicate your request by writing to the following address: info(Replace this parenthesis with the @ sign)apptweak.com.
Article 6 – What are your rights?
6.1. In the context of the processing of your personal data, you have the following rights:
- Right to access your personal data;
- Right to be informed about the purposes of the processing and the identity of the data controller;
- Right to rectify, complete or update your personal data. We encourage you from time to time to access your account (if applicable) or to consult us to check that your data is up to date;
- In certain circumstances, the right to delete your personal data (‘right to be forgotten’). You may, at any time request the deletion of your personal data, except those which we have a legal obligation to keep on record;
- Right to restriction of the processing of your personal data. You may, in particular, obtain a limitation of processing when you have objected to the processing, when you dispute the accuracy of the data, or when you consider that the processing is illegal;
- Right to the portability of your personal data. You have the right to receive the personal data that you have communicated to AppTweak and may also ask said company to send this data to another data controller;
- Right to object to the processing of your personal data;
- Right to withdraw your consent (if the legal basis for processing is consent);
- Right to lodge a complaint. You have the right to lodge a complaint about the way we process your personal data to the Belgian Data Protection Authority (DPA): Autorite de Protection des Donnees (APD), Rue de la Presse 35, B-1000 Brussels – contact(Replace this parenthesis with the @ sign)apd-gba.be – https://www.autoriteprotectiondonnees.be.
6.2. We do not subject data subjects to decisions based exclusively on automated processing which produces legal effects concerning them or similarly significantly affects them, including profiling.
In accordance with the GDPR and Belgian law, the exercise of these rights is in certain cases limited to certain assumptions or subject to compliance with certain conditions.
If you exercise some of your rights, AppTweak indicates that certain services may no longer be accessible or may no longer be provided – for example if you delete some information from your user account, some services may no longer be provided to you.
6.3. If you wish to exercise your privacy rights, please contact info(Replace this parenthesis with the @ sign)apptweak.com or, should you have any legal issue, our DPO: dpo(Replace this parenthesis with the @ sign)apptweak.com. We will then take the necessary steps to satisfy this request as soon as possible and within one month of receipt of the request. If necessary, this period can be extended by two months, given the complexity and the number of requests.
Article 7 – What security measures do we take?
7.1. AppTweak has taken the appropriate organizational and technical measures to ensure a level of security adapted to the risk and that, to the extent possible, the servers hosting the personal data processed prevent:
- unauthorized access to or modification of this data.
- improper use or disclosure of such data.
- unlawful destruction or accidental loss of such data.
7.2. Employees of AppTweak and AppTweak members who have access to this data are subject to a strict confidentiality obligation. Nevertheless, we may in no way be held liable in the event that this data is stolen or hijacked by a third party despite the security measures adopted.
7.3. Any breach of these security requirements may also constitute a violation of the Terms of Service of the SaaS Platform, Terms of Use of the Website, and Cookies Policy or, in general, the law. Violations of confidentiality, integrity, and availability of information systems and data shall be punishable by imprisonment of between three months and five years and a fine of between twenty-six euros and two hundred thousand euros, or one of these penalties only.
Article 8 – Do we disclose your data to third parties?
8.1. AppTweak treats personal data as confidential information and will not disclose it to third parties under any condition other than those specified in this Privacy Policy, such as to achieve the objectives set out and defined in Article 2, or under the conditions in which the law requires it to do so.
8.2. In this context, your personal data may possibly be communicated to the following persons or categories of persons:
- Payment and accounting partners
- Insurance providers
- CRM and communication tool
- User behaviour analytical tools
- Internal or external auditors
- Cloud service providers
- Social media platforms (such as LinkedIn)
- Recruiting platform/software
8.3. Should we transfer your personal data to third parties, the third party concerned will be required to use your personal data in accordance with GDPR and the provisions of this Privacy Policy.
8.4. Notwithstanding the above, it is however possible that AppTweak transfers your personal data in the following cases:
- To the competent authorities when we are required to do so on the basis of the law or within the framework of a judicial or administrative procedure. For example, we may need to exchange data with public authorities (including the judiciary, the police, and regulators) in the event of, for example, a cyber incident.
- To guarantee and defend our rights or allow third parties to defend their rights.
- If this proves necessary or desirable to meet legal or regulatory obligations.
- Where we or substantially all of our assets are taken over by a third party, in which case your personal data – which we have collected – will be one of the transferred assets.
- To our affiliates/other group entities.
- When you have expressly consented to it, if applicable.
8.5. The communication of this information to the aforementioned persons shall, in all circumstances, be limited to what is strictly necessary or required by the applicable regulations.
8.6. We do not sell any data.
Article 9 – Will we transfer data to a country outside of the European Economic Area?
9.1. AppTweak transfers data to a country outside the European Economic Area only when that country ensures an adequate level of protection within the meaning of the legislation in force and, in particular, within the meaning of the General Data Protection Regulation, or within the limits permitted by the legislation in force, for example by ensuring the protection of data by appropriate contractual provisions.
9.2. The information processed by AppTweak will be transferred or transmitted, or stored and processed, to our affiliates/members in the United States, Japan, India, UK, Canada and South Korea. We use standard contractual clauses approved by the European Commission and we rely on the European Commission’s adequacy decisions concerning certain countries. If you have any questions in this regard, do not hesitate to contact us at: dpo(Replace this parenthesis with the @ sign)apptweak.com.
Article 10 – Updates and changes to policy
10.1. We are authorized to update this Privacy Policy by publishing a new version on the Site, in particular, to comply with any new legislation and/or regulations applicable (such as the General Data Protection Regulation), the recommendations of the Belgian Data Protection Authority, the guidelines, recommendations and best practices of the European Data Protection Board and the decisions of the courts and tribunals on this issue.
10.2. In this context, you will be informed of any substantial modification subsequently made to the Privacy Policy. However, it is particularly advisable to regularly consult the Site and the relevant page on which the Privacy Policy is available, in order to be certain that you are aware of the slightest modifications.
Article 11 – Validity of the contractual clauses
11.1. Failure by AppTweak to invoke – at any given time – a provision of this Policy, may not be interpreted as a waiver of the right to subsequently make use of its rights under the said provision.
11.2. The invalidity, expiration, or unenforceable nature of all or part of one of the above or below-mentioned provisions shall not give rise to the invalidity of all the Privacy Policy. Any fully or partially invalid, lapsed, or unenforceable provision shall be deemed not to have been written. AppTweak undertakes to substitute this provision with another which, to the extent possible, fulfils the same objective.
Article 12 – Applicable law and jurisdiction
12.1. The validity, interpretation, and/or implementation of the Privacy Policy are entirely and exclusively subject to Belgian law, to the maximum extent permitted by the prevailing rules of private international law.
12.2. In the event of a dispute relating to the validity, interpretation, or implementation of the Policy, the courts and tribunals of Brussels (Belgium) have exclusive jurisdiction, to the extent permitted by the provisions of applicable private international law.
12.3. Before taking any step towards the judicial resolution of a dispute, the Data Subject and AppTweak undertake to attempt to resolve it amicably. To this end, they shall first contact each other before resorting, where appropriate, to mediation, arbitration, or any other alternative method of dispute resolution.
