Privacy Policy

Effective Date: October 13, 2023

1. Introduction

Candlestick Tech, LLC (referred to in this privacy policy as “Candlestick,” “we”, “us”, or “our”) provides certain integrations, interfaces, features, and other content that allow users to provide their feedback on certain advertisements served within participating third-party applications that users engaged with or downloaded (together with the Services defined below, the “Services”).  Within those applications, a window or pop-up may appear that enables users to review certain advertisements.  

This Privacy Policy (this “Policy”) describes the ways we collect, store, use, and disclose the information, including personal information, and data that our users (“users” or “you”) provide or we collect in connection with our website available at, the Candlestick software development kit (the “SDK”), the Candlestick application (the “App”), and any related integrations, interfaces, features, and content, including any text messages that you may receive from or on behalf of Candlestick (collectively, our “Services”). Additionally, this Policy describes your rights and choices concerning your information.

Please note that the scope of this Policy is limited to information and data collected or received by us through your use of the Services. We are not responsible for the actions of individuals with no relationship to us or third-party companies, the content of their sites, the use of information or data you provide to them, or any products or services they may offer. Any link to those sites does not constitute our sponsorship of, or affiliation with, those individuals or companies.

If you do not want us to collect, store, use, or share your information in the ways described in this Policy, you should not use our Services.

2. Personal Information We Collect From You and How We Collect It

Registration Information:

We collect and store any information you knowingly provide to us. For example, we collect your phone number and/or email address when you create an account, and use it to verify you, provide you with customer support, and send you marketing materials which may be of interest to you via texts / SMS ad/or email messages.

Feedback Information

Candlestick collects the feedback you provide regarding certain ads and may use it to facilitate the service of more personalized advertisements that better suit your interests and preferences.

Technical and Usage Information

When you access our Services, we may collect (i) certain technical information about your mobile device or computer system, including IP Address, mobile advertising ID (e.g., IDFA, Google Advertising ID or other identifiers), and the version of your operating system; and (ii) usage statistics about your interactions with the Services. In certain Services, we will create and assign to your device an identifier that is similar to an account number. We may collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as e-mail address. This information may be collected through the use of Candlestick or third-party mobile device SDKs. We may use this information to serve you targeted ads on participating applications. We may send you push notifications through our Service to send you App updates and other service-related notifications that may be of importance to you. You may at any time opt-out from receiving these types of communications by turning them off at the device level through your settings.

Information Collected by Customer Support

When you ask for assistance from our Customer Support team, we will collect and store the contact information you provide (generally your name and e-mail address), information about your gameplay or activity on the Services, and your user name. We will also store the correspondence and any information contained within.

3. How We Use Your Information

Our primary goals in using your information are to create your account, provide Services to you, send you marketing materials which may be of interest to you at the phone number you provided, serve you more relevant ads, troubleshoot or provide you with customer service support, improve and optimize our Services, contact you, conduct research and create reports for internal use. We use information collected through our Service for purposes described in this Policy or disclosed to you in connection with our Service. For example, we may use your information to:

  • Create accounts and allow users to use our Services;
  • Serve you more relevant ads;
  • Operate and improve our Services and any of our affiliates’ products and services;
  • Understand you and your preferences to enhance your experience and enjoyment using our Services;
  • Respond to your comments and questions and provide customer service;
  • Provide and deliver products and services you request;
  • Deliver advertising, marketing, and promotional information to you, including in text messages / SMS format at the phone number you provided;
  • Send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
  • Communicate with you about promotions and other news about products and services offered by us and our selected partners;
  • Conduct and administer contests promoted by us;
  • Link or combine it with other information we get from third parties to help understand your preferences and provide you with better services.

4. How We May Disclose Your Information to Third Parties

We may share information we collect or derive with third parties for the following purposes:

  • With service providers that perform services on our behalf or enhance our Services, including hosting services, payment processing, customer service and to assist us in our marketing efforts;
  • With advertising partners like advertisers, ad exchanges and other ad technology companies that require the data to select and serve our relevant advertisements to you and others, and assist us in our marketing efforts;
  • With our affiliates;
  • For analytics and research purposes, including Google Analytics. These service providers may use cookies to collect information about your online activities across this and other sites over time for non-advertising purposes. To learn more about how Google analytics collects and processes data and the choices Google may offer to control these activities, you may visit;
  • We may share aggregate or anonymous information about you with advertisers, publishers, business partners, sponsors, and other third parties;
  • With professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us;
  • When we have a good faith belief that we have to disclose the information in response to lawful requests by public authorities, including law enforcement or legal process purposes;
  • To satisfy any applicable laws or regulations;
  • When we believe in our sole discretion that our Services are being used in committing a crime, including to report such criminal activity or to share information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and other security precautions;
  • To protect our or a third party’s legal rights, investigate fraud, or to defend against a legal claim;
  • With acquirers and other relevant participants (and their advisors) in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Candlestick or our affiliates (including, in connection with a bankruptcy or similar proceedings); and
  • With your specified recipients. We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction.

We do not share your personal information except as approved by you or as described herein. Where we share your information with third-party service providers and business partners, we ensure that we have appropriate agreements in place to protect your information as required by applicable data protection laws.

5. Security Safeguards

We implement reasonable and appropriate technical and organizational measures to protect the security of your personal information against accidental or unlawful destruction, loss, change or damage.

However, no security system is impenetrable, and we cannot guarantee the security of your personal information.  Any transmission is at your own risk.

6. Data Retention

We retain your personal data for as long as needed to provide you Services, unless we are required by law to delete or if we accept your request to delete the information. We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements

7. Our Policy Regarding Children

We do not knowingly collect or solicit personal data from anyone under the age of 16 or knowingly allow such persons to use our Services. If you are under 16, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under the age of 16 may provide any personal data. In the event that we learn that we have collected personal data from a child under age 16, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of 16, please contact us.

8. Transfer of Personal Data Outside Your Country

We may transfer information that we collect about you to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, and we take steps to ensure adequate safeguards are in place to enable transfer of information to the U.S. and the use and disclosure of information about you, including personal data, as described in this Policy.

9. Lawful Basis for Processing

On certain occasions, we process your personal data when it is necessary for the performance of a contract to which you are a party, such as to provide the Services to you. We may also process your personal data to respond to your inquiries concerning our products and services.

On other occasions, we process your personal data where required by law. We may also process your personal data if necessary to protect your interests or the interests of a third party.

Additionally, we process your personal data when necessary to do so for fraud prevention, improving our network and services, and marketing our services to advertisers and publishers; where these interests are not overridden by your data protection rights.

If the processing of personal data is necessary and there is no other lawful basis for such processing, we will generally ensure that consent has been obtained from you. You have the right to withdraw your consent to processing of personal data at any time.

For questions about data processing, please contact our Data Protection Officer. Visit the “Contact Us” section below for contact information.

10. Specific Provisions for California Consumers

These additional provisions for California consumers apply only to individuals who reside in California.  The California Consumer Privacy Act of 2018 (“CCPA”) and California Privacy Rights Act of 2020 (“CPRA”) provide additional rights to know, access, correct, delete, and opt out, and requires “businesses” collecting or disclosing personal information to provide notice and a means to exercise those rights.

Your California Privacy Rights. California residents have the rights listed below under the CCPA. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

  • Information.  You can request the following information about how we have collected and used your Personal Information during the past 12 months:
    • The categories of Personal Information that we have collected.
    • The categories of sources from which we collected Personal Information.
    • The business or commercial purpose for collecting and/or selling Personal Information.
    • The categories of third parties to whom we disclose Personal Information.
    • The categories of Personal Information that we sold or disclosed for a business purpose.
    • The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose
  • Access.  You can request a copy of the Personal Information that we have collected about you during the past 12 months.
  • Correct. You can request that we correct any information on your account that is not accurate, complete, or updated by providing us with the necessary information to correct it.
  • Deletion.  You can ask us to delete the Personal Information that we have collected from you.
  • Opt-out of sales.  You can opt-out of any sale of your Personal Information.
  • Nondiscrimination.  You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.

Right to Opt Out of Information Sales

We do not “sell” information about our users as most people would commonly understand that term.  However, consistent with common practice among companies that operate online, we do “share” information in the sense that we allow certain third-party advertising networks and other third-party businesses to collect and disclose your personal information directly from your device through tracking technologies when you use our Services or otherwise engage with us. These third parties use your personal information for purposes of analyzing and optimizing our Service and advertisements on our websites, on other websites or mobile apps, or on other devices you may use, to personalize content or to serve ads that may be more relevant to your interests, and to perform other advertising-related services such as reporting, attribution, analytics and market research.  

How to Exercise Your Rights

To exercise your right to know, right to access, right to correct, right to delete, right to opt out of information sales, or any other right you may have under applicable law, please submit a request by emailing or by writing to us at the physical address in the “Contacts” section below, with the subject line “California Rights Request” and specifying which right(s) you would like to exercise (for example, your right to delete).  We will need to verify your identity before processing your request. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems. In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf where (i) you provide sufficient evidence to show that the requestor is an authorized agent with written permission to act on your behalf and (ii) you successfully verify your own identity with us.

We aim to respond to a consumer request within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.

11. Changes to This Policy

We are constantly changing and improving our Services. And we may update this Policy to reflect any changes to our data and information privacy practices. If we make any material changes we will notify you by means of a notice on the Services prior to the change becoming effective. We encourage you to periodically review this Policy for the latest information on our privacy practices. Please note that if we need to adapt the policy to legal requirements, the new policy will become effective immediately or as required.

13. Contact Us

Our Data Protection Officer

You may contact our Data Protection Officer at or at the address below for further information.

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