1. Who We Are

Proceed Interactive Marketing Group LTD (“the Company”, “We”, “Us”) operates the Appinions platform at appinions.com.

Registered Address: Althea Onoufriou Kliride 9, 6027, Larnaca, Cyprus
Registration Number: HE 371549 · Tax ID: CY 10371549L
Email: [email protected]
Phone: +357 99984410

We are the data controller responsible for personal data collected through appinions.com and the Appinions dashboard at dashboard.appinions.com.

2. What Data We Collect

2.1 Account Data
When you register for Appinions, we collect your name, email address, and password (stored encrypted). If you register via a third-party login, we receive basic profile information from that provider.

2.2 Payment Data
When you subscribe, payment is processed by our payment providers (Visa/Mastercard via JCC Payment Systems, and PayPal). We do not store your full card number. We retain only the last four digits, card type, and expiry date for reference. All payment data is handled by our payment processors in accordance with PCI-DSS standards.

2.3 Usage Data
We automatically collect data about how you use the platform, including pages visited, features used, session duration, IP address, browser type, device type, and operating system. This data is used to improve the platform and troubleshoot issues.

2.4 App Data You Submit
When you add apps to your Appinions account, we store the app identifiers, keywords, and competitor data you input. This data is used solely to provide the service to you.

2.5 Communications
If you contact our support team, we retain the content of those communications to resolve your issue and improve our service.

2.6 Cookies
We use cookies and similar technologies. See Section 8 for full details.

3. Legal Basis for Processing (GDPR)

As a company registered in Cyprus (European Union), we process your personal data under the following legal bases as defined by the General Data Protection Regulation (GDPR):

• Contract performance — to provide the subscription service you signed up for
• Legitimate interests — to improve the platform, prevent fraud, and communicate service updates
• Legal obligation — to comply with applicable laws including tax and anti-fraud requirements
• Consent — where you have explicitly agreed (e.g. marketing emails)

4. How We Use Your Data

We use your personal data to:

• Create and manage your account
• Process payments and manage your subscription
• Deliver the ASO analytics and keyword tracking service
• Send service notifications and product updates
• Respond to support requests
• Detect and prevent fraud or abuse
• Improve platform performance and features
• Comply with legal obligations

We do not sell your personal data to third parties. We do not use your data for advertising purposes unrelated to Appinions.

5. Who We Share Data With

Payment Processors — JCC Payment Systems (Cyprus) and PayPal process payments on our behalf. Your payment data is subject to their privacy policies.

Analytics Providers — We use Google Analytics 4 to understand platform usage. Data is anonymized before transmission where possible. You can opt out via the cookie consent banner.

Hosting and Infrastructure — Our platform infrastructure providers may process your data as part of service delivery, under strict data processing agreements.

Legal Requirements — We may disclose your data if required by law, court order, or to protect the rights and safety of our users or the public.

We do not share your data with advertisers, data brokers, or unrelated third parties.

6. Your Rights (GDPR)

As a user in the European Union or European Economic Area, you have the following rights:

• Right of access — request a copy of the personal data we hold about you
• Right to rectification — request correction of inaccurate data
• Right to erasure — request deletion of your personal data (“right to be forgotten”)
• Right to restriction — request that we limit processing of your data
• Right to data portability — receive your data in a structured, machine-readable format
• Right to object — object to processing based on legitimate interests
• Right to withdraw consent — where processing is based on consent, withdraw at any time

To exercise any of these rights, email: [email protected]

You also have the right to lodge a complaint with the Cyprus Commissioner for Personal Data Protection:
Website: www.dataprotection.gov.cy
Email: [email protected]

7. Data Retention

We retain your account data for the duration of your subscription and for up to 3 years after account closure, to comply with legal obligations and resolve disputes. Payment records are retained for 7 years as required by Cyprus tax law. You may request earlier deletion where no legal obligation requires retention.

8. Cookies

Appinions uses the following types of cookies:

Essential Cookies — required for the platform to function (session management, authentication). Cannot be disabled.

Analytics Cookies — Google Analytics 4 tracks usage patterns to help us improve the platform. These are only set with your consent via the cookie banner.

Preference Cookies — remember your settings and preferences between sessions.

You can manage your cookie preferences at any time via the cookie consent banner on our website, or through your browser settings. Withdrawing consent for analytics cookies does not affect your ability to use the platform.

9. Security

We implement appropriate technical and organisational measures to protect your personal data, including encrypted storage, HTTPS transmission, access controls, and regular security reviews. While we take security seriously, no system is completely immune to risk. If you suspect a security issue, contact us immediately at [email protected].

10. Children

Appinions is not directed at individuals under the age of 16. We do not knowingly collect data from children. If you believe we have inadvertently collected such data, contact us and we will delete it promptly.

11. Third-Party Links

The Appinions platform may contain links to the Apple App Store, Google Play Store, and other third-party websites. We are not responsible for their privacy practices. We recommend reviewing their respective privacy policies.

12. International Transfers

Our primary operations are based in Cyprus (EU). Where data is transferred outside the EEA (e.g. to Google Analytics infrastructure), we ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the European Commission.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by email and by updating the “Last updated” date at the top of this page. Continued use of the platform after changes take effect constitutes acceptance.

14. Contact

For any questions about this Privacy Policy or to exercise your data rights:

Proceed Interactive Marketing Group LTD
Althea Onoufriou Kliride 9, 6027, Larnaca, Cyprus
Reg. HE 371549 · Tax ID: CY 10371549L
Email: [email protected]
Phone: +357 99984410