Last modified: January 18, 2019
The responsible body according to art. 4 European General Data Protection Regulation (“GDPR”) is Adjust GmbH, Saarbrücker Str. 37a, 10405 Berlin, managing directors are Christian Henschel and Paul Müller.
In case of any questions relating to data protection, please get in touch with us at firstname.lastname@example.org or contact our Data Protection Officer Prof. Dr. Christoph Bauer directly at Große Bleichen 21, 20354 Hamburg, Germany or via e-mail at email@example.com.
This policy describes the types of information we may collect from you or that you may provide when you visit the website www.adjust.com (our “Website”) and our practices for collecting, using, maintaining, protecting and disclosing that information.
This policy applies to information we collect:
It does not apply to information collected by:
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.
Legal basis for the processing of this personal data is Art. 6 para. 1 (f) GDPR, as this data is necessary for the following purposes:
Furthermore, with this information we will be able to ensure the stability and security of our website.
We use information that we collect about you or that you provide to us, including any personal 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.
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 +49 172 153 501 1.
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:
Furthermore, we are tracking 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.
The technologies we use for this automatic data collection may include:
Additionally, we can receive information from third parties, for example business partners.
The information we collect on or through our Website may include:
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.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.
We store your data:
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may also disclose your personal information:
There is a transfer of data to third countries outside the European Union. This is done on the basis of statutory contractual provisions that are intended to ensure an adequate protection level of your data.
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:
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.
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.
California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to firstname.lastname@example.org or write us at: Adjust GmbH, Saarbrücker Str. 37a, 10405 Berlin, Germany.
In compliance with the Privacy Shield Principles, Adjust commits 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 Adjust at:
Adjust GmbH, Saarbrücker Str. 37A, 10405 Berlin, Germany
or by sending an email to email@example.com at any time.
We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions. Adjust has 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.
The Federal Trade Commission (FTC) has jurisdiction over our compliance with the Privacy Shield. Under certain conditions, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
We use the “visitor action pixels” from Facebook Inc. 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 Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook 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 Facebook 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 Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads in your account-settings. Facebook is certified under the US-EU Privacy Shield Agreement and thus guarantees compliance with European data protection legislation.
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. The sole purpose for passively collecting this information is to improve your experience when using our website. 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'.
VWO is operated by Wingfify Software Private Limited. VWO is a test and optimization tool with which businesses can conduct A/B Tests and develop behavioral geological targeting campaigns. This helps us to optimize and personalize our website. For this, VWO collects your IP address when you visit our website. Your IP address, however, is anonymized instantly. For more information, please click here. If you no longer want VWO to track your IP address when you visit our website, please use this opt-out link.
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 firstname.lastname@example.org.
Raygun is operated by Raygun Limited and is an online service providing us with error tracking and performance analytics for our Adjust Dashboard.
The only data that is shared with Raygun is the IP address of a Dashboard user. This information is used to compute geographic performance metrics limited to only the country of origin, that we use to improve the quality of our service. Raygun does not share data with any other third party.
If you would like to opt-out from our performance analysis and not to be tracked by Raygun please send a request to email@example.com specifying the email address associated with your Adjust Dashboard user.
Adjust GmbH, adjust Inc., adjust KK, adjust Korea Ltd., adjust (Beijing) Co Ltd., and adjust Ltd. (collectively, “Adjust” or “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:
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.