Adjust is user-privacy first
Our privacy record
We’ve been ePrivacy certified since 2015, renewing our current status at the end of 2017. According to their website, “since July 2016, [ePrivacy] certification covers the requirements of the General Data Protection Regulation (GDPR) for digital products.” As such, we’re certifiably GDPR ready, but our attitude to privacy goes beyond the letter of the law.
For example, we’re the only attribution service headquartered in the EU, and our German heritage goes hand-in-hand with privacy-first values. For instance, we run our own servers instead of handing our data to cloud services. This means we have total control of our client’s user data, all centralized in Europe.
Reasons we’re prepared for the GDPR
We have a dedicated privacy team
We handle data with care
We operate our own physical servers
We uphold the right to be forgotten
Users can now request to have their personal data deleted, at any time. This means that if you receive a request for account information deletion – this would have to be forwarded to us in order to fully comply with the request.
This can be done by implementing either of the following solutions:
What's considered personal data?
According to Art. 4(1) GDPR, personal data now includes various digital identifiers as ‘personal data’. Previously, name, photos, email and so on, were typical identifiers. Now, this list has expanded to include specifically:
- IP addresses
- Online identifiers
- A user’s location data
- Biometric data (fingerprints and retina scans)
- Behavioral and demographic profiling data
If your users consent to be tracked, you must protect this data.
A deletion policy, record of processing activities, and TOMs
All these are required by articles 17, 30 and art. 32 para. 4 GDPR. This includes, for example, measures like:
- Physical access control - Our physical data centers are secure. Security measures include having security officers onsite, monitoring and alarm systems, video/CCTV monitors and much more. No person, not even a member of Adjust, has self-determined access to the servers.
- Data access, usage and transmission controls - Tools in place to protect unauthorized access, usage or transmission of data. For example, we make sure that the data cannot be changed or deleted by unauthorized persons during transmission.
- Separation rule - To keep data private and secure we ensure that any information collected for different purposes is separate during processing. This extends to test systems and production systems as well.
- Pseudonymization - any data is hashed as early as possible. The processing of personal
data happens in a way that the data can no longer be assigned to a specific data subject without additional information being provided.
- Availability control and rapid recoverability - frequent backups protect all stored data
against loss. Adjust creates continuous backups, which are also transferred to a remote site. With this, Adjust can restore data if lost.
- Incident response management - if data is lost we inform those affected immediately.
While the content on this page is designed to help you understand the GDPR when working with third parties, the information contained should not be construed as legal advice. You should consult with your own legal counsel with respect to interpreting your unique obligations under the GDPR and the use of a company's products and services to process personal data.
For more on our GDPR compliance, get in contact with our privacy team - firstname.lastname@example.org.