Last modified: August 2023
The data controller 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 Beijing, China
● 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 firstname.lastname@example.org.
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 on the basis of art. 6 para. 1 lit. f) GDPR, 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
● For marketing and advertising 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 (website analysis)
● for other purposes that we specifically explain to you prior to collecting your 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 email@example.com.
From whom we receive your information
We receive the information from you (including about the devices you use). In addition, if we do not collect the personal data directly from you, we will also tell you the source of the personal data and, if applicable, whether it comes from publicly available sources.
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.
Technologies, which we use on this website
The technologies we use for this data processing 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.
Automated decision making (including profiling)
Automated decision-making - including profiling - does not take place.
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 withdraw 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 process the data for the fulfillment of a legal obligation, at most for as long as the legal obligation exists,
● 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:
● Consent Banners (“CMP”). You can grant and manage your cookie and consent preferences via the consent banner provided. Please note that we base the setting or processing of personal data using cookies on your consent in accordance with art. 6 para. 1 lit. a) GDPR, sec. 25 para. 1 TTDSG. In the case of cookies, which are absolutely necessary to make the website available properly, we base the setting of cookies on sec 25 para. 2 No. 2 TTDSG or the processing of personal data on our legitimate interest in accordance with art. 6 para. 1 lit. f) GDPR to make our website available and to ensure this and its functionality and user-friendly design.
● 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, for example, 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 in every email.
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 and object to the processing of your personal data (art 18 GDPR and art. 21 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 a supervisory authority (for example, the data protection authority responsible for us, which is the Berliner Beauftragte für Datenschutz und Informationsfreiheit at https://www.datenschutz-berlin.de/, Art. 77 GDPR).
If you have given your consent to the processing of your data, you can withdraw the given consent at any time (art.7 para.3 GDPR) by sending us an email to firstname.lastname@example.org. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
You can object to the processing of your personal data insofar as we base the processing of your personal data on our legitimate 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.
Of course, you can object to the processing of your personal data for direct marketing 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 (Standard Contract Clauses) or other suitable guarantees, such as certifications or proven compliance with international security standards. Information on this is available from us upon request.
Data Privacy Framework
In compliance with the DPF Principles, we are committed to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our DPF 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 DPF 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 Gordon House, Barrow Street, Dublin 4, Ireland 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 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".
In addition to the option to reject Google Analytics in our Consent Banner, you can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
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 also use the Google Analytics advertising features (remarketing) from Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. 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 withdraw 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.
Further information and setting options for personalized advertising at Google can be found here: https://support.google.com/My-Ad-Center-Help/answer/12155451?hl=en&sjid=174251308182856932-EU.
We 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)
LinkedIn Insight Tag
Marketing Cloud Account Engagement (formerly Salesforce Pardot)
Hotjar Ltd. Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian’s STJ 3141, Malta, provides a service which analyses the online behavior of website users by combining analytics and feedback tools.
We use Universal Event Tracking (UET) on our website via the Microsoft Advertising service of Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. 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 . Microsoft offers the opportunity to opt out under https://account.microsoft.com/privacy/ad-settings/signedout?lang=en-US.
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. 6sense enables us to identify and target B2B prospects who have shown interest in our services. This allows us to optimize and improve our marketing strategy.
3. Other Recipients
We use the consent technology of Usercentrics A/S, Havnegade 39, 1058 Copenhagen, Denmark (hereinafter "Cookiebot") to obtain consent for the storage of certain cookies on your terminal device or for other actions requiring consent and to document and manage these in accordance with data protection laws. The purpose of the data processing is the analysis, management and proof of the consents granted, in order to comply with our obligation of a GDPR-compliant consent management.
Among other things, your IP address (in anonymized form, the last 3 digits are set to 0), the date and time of your consent, our website URL, technical browser data, an encrypted anonymous key and the cookies you have allowed (as proof of consent) are processed.
Facebook Lead Ads
We use Facebook Lead Ads from Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. Users may submit their contact information to us through certain advertisements, which we then process for promotional and advertising purposes. For more information visit: https://www.facebook.com/policy.php.
LinkedIn Lead Gen Forms
LinkedIn, meaning LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Irland, offers Ads that allow people to submit their contact and other information to us ("Lead Gen Forms"). We process the data transmitted to us for advertising purposes. You entered data will also be processed by LinkedIn. For more information visit: https://linkedin.com/legal/privacy-policy.
Amplitude is an analysis service of Amplitude Inc., 201 3rd Street, Suite 200, San Francisco, CA 94103, USA. 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.
We operate a Facebook page (so-called "Fanpage") on Facebook, a service of Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2,
Meta collects and uses data to provide analytics services, known as "page insights," to site operators to help them gain insight into how people interact with their sites and the content associated with them. This data includes information about the types of content users view or interact with, or the actions they take, as well as information about the devices users use, such as IP addresses, operating system, browser type, language settings, cookie data.
We are jointly responsible with Meta Platforms Ireland Ltd. for the collection and processing of data of visitors to our Fanpage. The legal basis for this processing is our legitimate interest in improving the user experience when visiting our Fanpage, in effective promotional activities using social media and communication about specific products, and measuring and adjusting such activities., art. 6 para. 1 lit. f) DSGVO. We have therefore concluded a joint controller agreement with Meta regarding the processing of your data pursuant to Art. 26 DSGVO. The agreement with Meta also regulates in particular which security measures Meta must observe and that Meta must fulfill the data subject rights.
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 for this processing is our legitimate interest in improving the user experience when visiting our LinkedIn Page, in effective promotional activities using social media and communication about specific products, and measuring and adjusting such activities, art. 6 para. 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.