Last modified: March, 2023
The responsible body according to art. 4 European General Data Protection Regulation ("GDPR") is Adjust GmbH, Saarbrücker Str. 37a, 10405 Berlin, managing director is Simon Dussart.
Responsible for data processing in contracts with your respective contractual partner:
- Adjust GmbH, Germany
- Adjust Software Ltd, United Kingdom
- Adjust Inc., United States
- Adjust KK., Japan
- Adjust Brasil Licenciamento de Software Ltda., Brazil
If one of our subsidiaries is the data controller and the registered office is outside the EU, its EU Representative is Adjust GmbH, Saarbrücker Str. 37A, 10405 Berlin, Germany
If the data processing is subject to the UK GDPR and a UK Representative is required this is Adjust Software Ltd, 90 High Holborn, Holborn, London, WC1V 6LJ, United Kingdom
In case of any questions relating to data protection, please get in touch with us at email@example.com.
Our external Data Protection Officer is ePrivacy GmbH, represented by Prof. Dr. Christoph Bauer, Große Bleichen 21, 20354 Hamburg. If you wish to communicate directly with our Data Protection Officer (because you have a particularly sensitive matter for example), please send your request to them by post. Please state in your request that your concern relates to the company Adjust GmbH.
1. Collection and Use of Data
Personal data is all information relating to personal and objective circumstances through which a person may be personally identified. This may for example entail information such as your name, address or other contact details such as phone number or e-mail address.
We base the processing of your data on the following legal bases:
- Your consent, if you have given us such consent (Art. 6 para. 1 lit. a) GDPR),
- The initiation or execution of a contract with you (Art. 6 para. 1 lit. b) GDPR),
- The fulfilment of legal obligations (Art. 6 para. 1 lit. c) GDPR),
- The implementation of our legitimate interests (Art. 6 para. 1 lit. f) GDPR)
When processing your data, we pursue the following legitimate interests:
- To present and improve our website
- To estimate the size of our target group and their user pattern
- To save information about your preferences so that we may adapt our website to your individual interests
- To speed up your search
- To recognize you when you return to our website
Furthermore, with this information we will be able to ensure the stability and security of our website.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
- To present our Website and its contents to you
- To provide you with information, products or services that you request from us
- To fulfill any other purpose for which you provide it
- To target audience and for marketing purposes
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection
- To notify you about changes to our Website or any products or services we offer or provide through it and to help us understand how the Website is being used
- In any other way we may describe when you provide the information
We may also use your information to contact you about goods and services that may be of interest to you. If you do not want us to use your information in this way, you may elect to unsubscribe and we will cease using your information in that manner.
Children Under the Age of 13
Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at Adjust GmbH, Saarbrücker Str. 37a, 10405 Berlin, Germany, via email at firstname.lastname@example.org or per phone at +49 173 801 480 5.
Information We Collect About You
We collect several types of information from and about users who visit our Website via internet connection or through your device which you use to access our Website, including certain user details. Such information includes:
- Traffic data
- Server logs
- Resources on our website which you access and use
- IP address, operating system and browser type
and information which is collected through cookies, web-beacons and other tracking technologies.
Furthermore, we are processing data with which you may be personally identified such as your name, postal address, e-mail address, phone number and any other identifier with which you may be contacted online or offline ('personal data') insofar as you provide us with this data in our online form. Keep in mind that we also handle correspondence and process data to that respect.
The technologies we use for this automatic data collection may include:
- Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit Adjust, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
- Log files. Every time you access our Internet pages, your usage data is transmitted through the respective internet browser and stored in log files, the so-called server log files. The records stored in this case contain the following data: domain and location from which the user is accessing the website
Information You Provide to Us
The information we collect on or through our Website may include:
- Information that you provide by filling in forms on our Website. This includes information provided at the time of subscribing to our newsletter, subscribing to our service, or requesting further services. We may also ask you for information when you report a problem with our Website or the Adjust technology
- Records and copies of your correspondence (including e-mail addresses), if you contact us
- Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website
- Details of Website searches and button clicks are also recorded
You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Requirement or Obligation to Provide Data
Unless this is expressly stated, the provision of your data is not required or obligatory.
Duration of Retention of Data
We store your data:
- If you have consented to the processing at the latest until you revoke your consent
- If we need the data to carry out a contract at most as long as the contractual relationship with you or statutory retention periods are running
- If we use the data on the basis of a legitimate interest at most as long as your interest in deletion or anonymization does not prevail
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
- To our subsidiaries and affiliates for the sole purpose of providing our services.
- To contractors, service providers and other third parties we use to support our business:
- Provider of web analysis tools
- Web hosting and web development providers
- Marketing and advertising service providers
- E-mail and newsletter provider
- Service provider for editing and translations
- CRM system service provider
- Cloud services
- Payment service provider,
- Conference and Webinar Software
- Service provider for online surveys
- Service provider for chat software
- Social media platforms
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Adjust's assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Adjust about our Website users is among the assets transferred.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your personal information:
- To comply with any court order, law or legal process, including to respond to any government or regulatory request
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Adjust, our customers or others
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Opt-out. You may "opt out" of receiving marketing or promotional emails from us by following the instructions in those emails. If you opt out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations
- We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.
How we protect Your Data
- We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. All transactions, regardless of their nature, are encrypted using SSL technology
- The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone
- Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
- Transfer between subsidiaries: We may transfer user and customer information to our affiliates and to third party providers for the sole purpose of providing our services
If you subscribe to our newsletter, we will process your e-mail address and data to verify your subscription. You can cancel your subscription at any time by sending a message to us or by clicking the 'unsubscribe' button.
Your rights according to the GDPR
As the data subject, you have the right of access (Art 15 GDPR), the right to rectification (Art 16 GDPR), the right to erasure of your personal data (Art 17 GDPR), the right to restriction of processing of your personal data (Art 18 GDPR) as well as the right to data portability (Art 20 GDPR). Furthermore, you have the option to file a complaint against the processing of your personal data with the competent supervisory authority (in this case Berliner Beauftragte für Datenschutz und Informationsfreiheit at https://www.datenschutz-berlin.de/).
If you have given your consent to the processing of your data, you can revoke the given consent at any time. Such revocation affects the admissibility of the processing of your personal data after you make such revocation.
You can object to the processing of your personal data insofar as we base the processing of your personal data on the balance of interests. This is the case in particular if the processing is not necessary for the fulfilment of a contractual obligation to you, which we in each case present in the description of the functions which follow. In case of such objection, we kindly ask for an explanation of the reasons for the objection against the processing of your personal data. In the case of your justified objection, we will examine the situation and will either discontinue or adapt the data processing or point out to you our compelling legitimate reasons based on which we continue the processing your personal data.
You may, of course, object to the processing of your personal data for advertising and data analysis purposes at any time. In this case, please send an e-mail to email@example.com.
Your California Privacy Rights
If you are a California resident, please review our California Resident Privacy Notice ("CCPA") for information regarding your California privacy rights.
Transfer to Third Countries
If personal data is being transferred to countries outside the European Economic Area, we only transfer it to third countries where the EU Commission has confirmed an adequate level of protection or where we can ensure the careful handling of personal data by means of contractual agreements or other suitable guarantees, such as certifications or proven compliance with international security standards.
Privacy Shield Framework
In compliance with the Privacy Shield Principles, we are committed to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at: firstname.lastname@example.org
We have further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU. We are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). You have the possibility, under certain conditions, to invoke binding arbitration. Please be aware, that we are required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Furthermore, we take liability in cases of onward transfers to third parties.
2. Tracking Technologies on our Website
We use the Google Analytics service of the provider Google Ireland Limited (Google Ireland/EU) on our website.
Some of this data is information that is stored in the terminal device you are using. In addition, further information is also stored on your end device via the cookies used. Such storage of information by Google Analytics or access to information that is already stored in your terminal device only takes place with your consent.
Google Ireland will process the data collected in this way on our behalf in order to evaluate the use of our website by the users, to compile reports on the activities within our website and to provide us with further services associated with the use of our website and the use of the internet. In doing so, pseudonymous usage profiles of the users can be created from the processed data.
The setting of cookies and the further processing of personal data described here takes place with your consent. The legal basis for the data processing in connection with the Google Analytics service is therefore Art. 6 (1) a GDPR. You can revoke this consent via our consent management tool (“Data Preferences” at the bottom on our website) at any time with effect for the future.
The personal data processed on our behalf to provide Google Analytics may be transferred to any country in which Google Ireland or Google Ireland's sub-processors maintain facilities. Please note the information in the section "Data transfer to third countries".
We use the Google Analytics 4 variant, which allows us to track interaction data from different devices and from different sessions. This allows us to put individual user actions in context and analyze long-term relationships.
The data about user actions are stored for a period of 14 months and then automatically deleted. All other event data is stored for 2 months and are then automatically deleted. Thereby, the deletion of the data whose storage period has expired takes place automatically once a month.
We use the online advertising program Google Ads of Google Ireland Limited (Ireland, EU) on our website, through which we place advertisements on the Google search engine. When you access our website via a Google ad, Google sets a cookie on your terminal device ("conversion cookie"). In the process, a different conversion cookie is assigned to each Google Ads customer, so that the cookies are not tracked across the websites of different Ads customers. The information obtained with the help of the cookie is used to create conversion statistics. This tells us the total number of users who clicked on one of our Google ads. However, we do not receive any information with which users can be personally identified.
The processing of your data is based on your consent according to Art. 6 para. 1 letter a GDPR.
We also use the Google Analytics advertising features (remarketing). This function enables us, in conjunction with the cross-device functions of Google, to display advertisements in a more targeted manner and to present users with ads that are tailored to their interests. Via the remarketing, users are shown ads and products for which interest has been identified on other websites in the Google network. The function allows us to link advertising target groups created via Google Analytics Remarketing with the cross-device functions of Google Ads. In this way, interest-based, personalized advertising messages that have been adapted to a user depending on previous usage and surfing behavior on an end device (e.g. cell phone) can also be displayed on another end device of the user (e.g. tablet or PC).
If you have given your consent, Google will link your web and app browsing history with your Google account for this purpose. In this way, the same personalized advertising messages can be placed on every end device on which you log in with your Google account. The aggregation of the collected data in your Google account is based solely on your consent, which you can give or revoke at Google. For these linked services, data is then collected via Google Analytics for advertising purposes. To support the remarketing function, Google Analytics collects users' Google-authenticated IDs, which are temporarily linked to our Google Analytics data. This is used to define and create target groups for cross-device ad advertising.
We also use the Signals feature of Google Analytics, a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Signals recognises individual users using different devices (so-called cross-device tracking). We only receive anonymous data in the form of a report that shows patterns in user behaviour. Google Signals helps us to better understand how visitors interact with our website and to show more meaningful and personalized ads to these visitors after leaving our website.
For this, session data is being processed and linked with website visitors that
• have a Google account;
• are logged in to their Google account when they access the corresponding website; and
• have turned on the “Ads personalization” feature in their Google account.
If you do not wish to be subject to the Signals feature, you can deactivate the “Ads personalization” feature in your Google account.
Meta Pixel (formerly known as Facebook Pixel)
We use the "visitor action pixels" from Meta Platforms Inc. ("Meta") on our website. This allows user behavior to be tracked after they have been redirected to our website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Meta, which is why we are informing you, based on our knowledge of the situation. Meta may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook's Data Usage Policy. You can allow Meta and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes. You can object to the collection of your data by Meta pixel, or to the use of your data for the purpose of displaying Facebook ads in your account-settings.
LinkedIn Insight Tag
Bizible offers an integrated marketing analysis platform for marketers in order to optimize their advertising campaigns. Bizible collects your name, e-mail address and (if applicable) your address (only if you have explicitly provided us with this), as well as IP address, browser type and marketing source. You can do a Bizible Cookie-Opt-Out here. For more information, please klick here.
Clearbit is operated by APIHub Inc. Clearbit has developed a business intelligence API to aid businesses in acquiring more information about their clients in order to increase turnover and reduce fraud. Clearbit collects your IP address so that we may improve our website. For more information and to have yourself removed from the Clearbit database, please click here.
Hotjar Ltd. provides a service which analyses the online behavior of website users by combining analytics and feedback tools.
Hotjar will collect and processe your IP address when you navigate through and interact with the contents of our website and to evaluate the use of Adjust Dashboard. The sole purpose for passively collecting this information is to improve your experience when using our website and Adjust Dashboard. You may opt-out from having Hotjar collect Your information when visiting our website at any time by visiting their Opt-out page and clicking 'Disable Hotjar'.
Drift Inc. is a conversation-driven marketing platform. With its rapidly evolving tools, Drift unlocks the hidden insights to accelerate business success. Drift records the email address you enter in our forms. For more information on how drift data is collected and processed please click here. To unsubscribe from drift tracking, please email email@example.com.
Yahoo Ads for Japan
Users can halt the use of the cookie information and advertising ID etc. to ad delivery by Adjust with the following procedure:
For browsers: Access the opt-out page on website of the third party.
For apps: Access the advertising ID setting screen.
For the details of setting, refer to the guidance on Apple, Google, etc. that provides OS for each device.
We use Universal Event Tracking (UET) on our website via the Microsoft Advertising service of Microsoft Corporation (USA). Via UET, Microsoft stores a cookie in the user's browser to enable an analysis of the use of our online offer. The prerequisite for this is that the user has reached our website via an advertisement from Microsoft Advertising. In this way, we and Microsoft can recognise that someone has clicked on an ad, has been redirected to our online offer and has reached a previously determined target page (conversion measurement). No IP addresses are stored in this process. No further personal information about the identity of the user is communicated either.
For more information on data protection at Microsoft, please refer to Microsoft's privacy statement at http://privacy.microsoft.com/en/privacystatement . The legal basis for the use of this service is Art. 6 para 1 sentence 1 lit. f) GDPR. If you do not wish to participate in the Microsoft Ads tracking process, you can communicate your objection to Microsoft here: http://choice.microsoft.com/de-DE/opt-out.
We use 6sense, a marketing automation software on our website. The service is provided by 6sense Insights, Inc., 450 Mission Street, San Francisco, CA 94105, United States.
The data shared with 6sense includes cookie and other online identifiers, names, email addresses, phone numbers, social media contact information, company names, customer status, industry and job descriptions, websites visited, location information, and commercial interests. We process this data based on your consent as well as based on our commercial marketing interests. You can find more information about the data processed by 6sense at https://6sense.com/privacy-policy/.
3. Other Recipients
Facebook Lead Ads
We use Facebook Lead Ads from Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland for advertising purposes. Therefore, we process contact information from you. To revoke your consent please send us an email. You entered data will also be processed by Meta. We have no influence on the data collected and their processing. For more information visit: https://www.facebook.com/policy.php.
LinkedIn Lead Gen Ads
LinkedIn offers Ads that allow people to submit their contact and other information to us ("Lead Gen Forms"). Therefore, we process contact information from you. To revoke your consent please send us an email. You entered data will also be processed by LinkedIn. We have no influence on the data collected and their processing. For more information visit: https://linkedin.com/legal/privacy-policy.
Amplitude is an analysis service of Amplitude Inc. (631 Howard Street, Suite 300, San Francisco, CA 94105, U.S.A.). This tool collects technical information, such as the type of your device (e.g., iPhone 7 or the operating system used (e.g., iOS 10.3). In addition, Amplitude tracks location data (e.g. country) and internal data (e.g. language, server upload time, session ID) that occur when using our Adjust Dashboard. Such events may, for example, be how long you were logged into our Dashboard and from which country. In other words, Amplitude helps us understand how you use our Dashboard so we can improve the experience. You will find additional information about the manner in which Amplitude processes data at: https://amplitude.com/privacy.
When you visit our Facebook Pages, which we use to represent our company or individual products or services, some of your personal data will be processed. The sole controller responsible for the processing of personal data is Meta Platforms Ireland Ltd (4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland, "Meta"). Further information about the processing of personal data by Meta can be found at https://www.facebook.com/privacy/explanation.
Processing of Page Insights:
Meta provides us with anonymized statistics and insights for our Facebook page, which help us to understand the types of actions that people take on our Page (so-called "Page Insights"). These Page Insights are created based on specific information about individuals who have visited our Page. This processing of personal data is carried out by Meta and by us as joint controllers. The processing serves our legitimate interest to evaluate the types of actions being taken on our Page and to improve our Page based on these findings. The legal basis for this processing is Article 6 paragraph 1 letter f GDPR. We are in no case able to assign the information obtained via Page Insights to a specific Facebook profile using the "Like" data for our Page. We have reached an agreement with Meta to share joint responsibility for the processing, in which the division of data protection obligations between ourselves and Meta is set out. Details about the processing of personal data for creating Page Insights and the agreement entered into between ourselves and Meta can be found at https://www.facebook.com/legal/terms/information_about_page_insights_data.
We operate a LinkedIn page on LinkedIn, a service of LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland.
LinkedIn collects and uses data to provide analytics services, known as "page insights", to site operators to help them understand how people interact with their pages and with the content associated with them. This data includes information about the types of content that users view or interact with, or the actions they take, as well as information about the devices used by users, such as IP addresses, operating system, browser type, language settings, cookie data.
We are jointly responsible with the LinkedIn Ireland Unlimited Company for the collection and processing of information about visitors to our page. The legal basis is our legitimate interest in this information for advertising purposes, Art. 6 para. 1 p. 1 lit. f. GDPR. We have therefore concluded an agreement with LinkedIn on joint responsibility with regard to the processing of your data in accordance with Art. 26 GDPR. In particular, the agreement with LinkedIn also regulates which security measures LinkedIn must observe and that LinkedIn must comply with the rights of data subjects.
4. Processing of data through the Adjust Technology
We provide mobile analytics and attribution services to mobile app providers (our "Customers"). In connection with these services, we may process certain data from the users of these mobile apps (collectively the "End User" or "You"), as further described hereafter. We process the data upon instructions from our Customers and do not have any kind of direct relationship with the You as the End User.
Customers who have child directed apps must choose the appropriate product settings and must not share any personal data with Partners or any third parties. Customers must agree to the section in our Terms and Conditions accordingly.
Our SDK and APIs (collectively the "Adjust technology") may process some of the following data from You as the End User:
- Hashed IP address
- Mobile identifiers such as the ID for Advertising for iOS (IDFA), Google Advertising ID or similar mobile identifiers
- Installation and first opening of an app on Your mobile device
- Your interactions within an app (e.g. in-app purchases, registration)
- Information regarding which advertisements You have seen or clicked on
- For the Unbotify/Fraud product additionally: sensory data including touch events, counting text changes, accelerometer, gyroscope, battery, light sensor, device hardware specifications and operating system version
We use the aforementioned data for providing mobile analytics and attribution services to our Customers, and thereby allow our customers to track their marketing performance, to match You to their campaigns and to understand how You engage with our Customer's app. Furthermore, we enable our Customers to track Your interactions in their apps in real time in order to see how You engage over their full lifetime. The aforementioned data is therefore processed in order to analyze the performance of marketing campaigns and to provide performance reports to our Customers. We do not combine the data with any other data that would enable us to personally identify You. Any information processed via the Adjust technology is owned and controlled by our Customer who has implemented the Adjust technology into their mobile app.
We do not share or disclose the user data with anyone else except with our server providers and in response to lawful requests by public authorities, including national security or law enforcement requirements. We store the data as long as our Customers are using the Adjust technology because we need it to provide our services to our Customers, if not requested otherwise by our Customers.
In some cases, there is a transfer of data to third countries outside the European Union. This is done on the basis of statutory provisions that are intended to ensure an adequate level of protection for Your personal data.