Updated March 1, 2023

This is the Privacy Policy for the platform. Your privacy is important to us and we are committed to protecting and respecting your privacy and personal data.

INTRO is an analytics platform that aggregates data on marketing costs and financial transactions from sold the Customer’s Application subscriptions, including an algorithmic component that allows you to obtain predictive financial metrics in terms of the Customer’s marketing campaigns (“Platform”) offered by PREDICTED-IO LIMITED together with any of its affiliates or subsidiaries (“Company”, or “us”, or “we”).

The primary purpose of our Privacy Policy (“Policy”) is to provide a clear picture of what data we collect, how it is used, and how you can control it. 

The Policy may be amended from time to time.  If we make any material changes, we will notify you by email, via the Platform, or by any other available means. Your continued use of the Platform after the effective date of an updated version of the Policy will indicate your acceptance of the Policy as modified. In some cases, you will have to accept changes to the Policy explicitly. Please review the website for the latest updates on our data privacy practices. If you do not accept the terms of the Policy, we ask that you do not use the Platform.


Our mission is to make it clear what we do with your data is transparent and easily understandable to you, our customer.

Unless specifically indicated elsewhere in this Policy, the Company acts as a processor to your data and you act as a sole controller. 

We will process your data to provide you with the prediction of marketing and financial metrics, collect all important business information in one place, so you could make more informed decisions about your business directions and marketing campaigns (“Services”).

In order for us to carry out Services as described above, you may authorize us to collect the data from various third-party systems including, but not limited to:

Type of third-party systemNameData collectedPurpose of processing Legal basis for processing
Media and marketing sourcesFacebook Ads Manager

Apple Search Ads

TikTok for Business

Pinterest for Business

Twitter for Business

Snapchat for Business

Google Ads
Spend data: e.g. how much you spend on a particular marketing campaign.
Impressions: how popular your campaign was and how many displays it had.
Clicks: how many clicks your ad had.
To aggregate the data from media and marketing sources as a part of the ServicesProcessing to fulfill our contractual arrangements with you as well as the legitimate interest in doing so, whatever is more applicable to each case of processing
Mobile measurement platformsAppsflyer


Unique device identifiers for advertising (Google Advertiser ID or IDFA, for example)
Device information including location data, time of installation, operation system data
Usage data as processed by each specific system and as instructed by you
To understand and analyze the conversion rates and other statistics and measurements related to your marketing campaignsProcessing to fulfill our contractual arrangements with you as well as the legitimate interest in doing so, whatever is more applicable to each case of processing
StoresApp Store

Google Play Market
Statistics on purchases within our customer’s services or applications
Refunds statistics
To understand your metrics around subscription, purchases, and refunds in order to render the ServicesProcessing to fulfill our contractual arrangements with you as well as legitimate interest in doing so, whatever is more applicable to each case of processing
Subscription serversStripe





iOS/Android subscription server
Location data 
Status of purchase (subscriptions
Cancellation of subscription
Billing issues
Change of subscription
Other events or data as you may instruct this type of third parties to process
To gather real-time statistics on purchases and overall payment behavior in order to render the ServicesProcessing to fulfill our contractual arrangements with you as well as the legitimate interest in doing so, whatever is more applicable to each case of processing

Besides that, we may also collect and process the following data in order to run our Services in accordance with the purposes highlighted above:

All data indicated in this section, including End-user data, is hereinafter referred to as ‘data’ or ‘your data’.


We would like to improve our Services to make your business decisions more informed and well-taken as well as to have your experience with our product as smooth as possible. 

For that reason, we may need your data from time to time to:

Purpose of processingLegal basis for processing
Check data correctness;Legitimate interest to provide Services conformant to your expectations and our commercial agreements
Actualize and improve our prediction model incorporated into the Platform;Legitimate interest to run effective and bug-free Services
Analyze it for the general improvement of our Services and the Platform;Legitimate interest to run effective and bug-free Services
Send you technical notices, updates, security alerts and support and administrative messages;Our agreement with you
Provide customer support;Our agreement with you
Monitor and analyze trends, usage and activities in connection with our Platform;Legitimate interest
Send you promotional materials, discount information, or commercial offers. 
Please note that you MAY OPT-OUT ANY TIME from such communications by clicking the ‘opt-out’ button or link in any respective message or email sent you by us, or by reaching us to the contact details provided in the Policy.
Legitimate interest
Verify your user identity, legal standingLegal obligation
Maintain securityLegitimate interest to keep our Services safe

Please note that for the purposes of this section we may act not only as a processor but also as a controller or a co-controller with you. For the purposes indicated in this section and the previous one, we may attract processors (service providers) acting solely on our behalf. 

Here is the list of such processors:


We will retain your data as long as your account is active or needed to provide you Services.

If you choose to deactivate your account or terminate our agreement we will retain your data for a reasonable period in case you decide to re-activate the Services unless you decide to delete your data as specified by the Policy. After the expiration of this period we will aggregate and anonymize all our data (including End-user data) and will only retain it as needed for some of the purposes indicated in the section above.

We may also retain certain categories of your data (excluding any identifiable End-user data) and other information after your account has been terminated or deleted as necessary to comply with legal obligations, resolve disputes, and enforce our agreements.


We use third-party providers and services to store your data. Some of the servers where your data is stored may be located in counties that may not offer the same protections as the law of your jurisdiction. You consent and authorize us to store your data in such a manner.

We commit to affording your data with the requisite level of protection, e.g. using standard contractual clauses and other available recourse mechanisms.

We may store your data in the USA, Germany, United Kingdom and Finland depending on your particular case.


It does not matter what country or region you come from. We are committed to providing you vast privacy rights with respect to your data.

Please note that some laws may require us to perform any other action not specifically mentioned in this section as well as to limit the scope of the exercise. In such cases, we will try to match your request with the highest possible standards prescribed by the Policy but reserve a right to exercise your rights within the limits of the laws that apply to your case.

Also keep in mind that if we receive a vague request, we may engage you to better understand the motivation and content of the request. We may also refuse manifestly unfounded and excessive (repetitive) requests.


We are committed to protecting the privacy of children. The Services are not intended for children and we do not intentionally collect information about children under 16 years old.

Please contact us at if you become aware that anyone under 16 years old uses the Services and his, her or their data is being processed by us. We will take the required steps to delete such information and (or) delete her account.  

We undertake to respect any privacy limitations on the processing of minors’ data that apply in your jurisdiction.

You are specifically forbidden to provide us any data that does not comply with this section of the Policy. It is your sole responsibility to make sure no minor data is processed via our Services. Violating such obligations may result in the early termination of our mutual contractual arrangements.


We take all reasonable and appropriate measures to protect all data we collect from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction.

Among other things, we use the following measures to protect the security of your data:

Please understand that you can help keep your data secure by choosing and protecting your password appropriately, not sharing your password, and preventing others from using your device. Please understand that no security system is perfect and, as such, we cannot guarantee the absolute security of our Services, or that your information will not be intercepted while being transmitted to us. 

If you want to report a security incident related to the Services or the Platform please contact us at


To communicate with our Data Protection Officer, please email Alexei Shevnin ( or use the contact details below. 


General contact details. If you have any questions or concerns about your privacy, any provisions of this Privacy Policy or any of your rights, you may contact us at:

PREDICTED-IO LIMITED, registration number HE 425756

Our address: Spyrou Kyprianou, 78, Magnum Business Center, 3rd floor, 3076, Limassol, Cyprus