AdAdapted, Inc., its subsidiaries, and affiliates (known as “AdAdapted,” ”We,” “Our,” or “Us”) collects certain personal information as part of our business and native advertising solution (“Services”). This information allows us to deliver relevant advertising to mobile grocery shoppers. We take seriously our responsibility to facilitate privacy rights fairly under applicable law.
Scope and Applicability
Information We Collect and Receive
AdAdapted may collect certain personal information directly or indirectly based on your specific relationship with us.
We collect or receive the following categories of personal information (“Business Data”) from your use of our website and your related interactions with us:
|Log Data||Information collected by our servers when you access our website, including IP addresses, referral URLs, browser type and settings, date and time of usage, language preferences, and cookie data|
|Device Data||Information about your device, including type of device, operating system, application IDs, unique device identifiers, and crash data|
|Analytics Data||Approximate location based on your IP address and other information from your browser and device|
|Contact Information||Your name, phone number, email address, and mailing address, etc. if you engage with us through our webforms or other contact methods|
Publisher Partner App Users
AdAdapted receives certain personal information (“App Data”) from our Publisher Partners through our SDK installed by our Publisher Partners in their mobile applications:
|User and Mobile Advertising IDs||Device IDs (e.g. uDID) and “IDFA”|
|Device Data||Information about your device, including type of device, operating system, platform, carrier, time zone, IP address, and device properties|
|Analytics Data||Approximate location (i.e. latitude/longitude, area code, postal code, city, country, area code, and region)|
|Interaction Data||In-app interactions (i.e. product interactions, inputted list data, and searches)|
|Advertising Data||Advertising campaign information and advertising interactions|
|Usage Data||Event time stamps, log data, SDK diagnostic data, crash data|
Our Uses of Personal Information
Business Data is used for providing our Services and operating our business, which includes the following purposes:
- Administering our Service and customer accounts
- Communicating through email and other means
- Promoting AdAdapted through sales and marketing
- Detecting and preventing abuse and security issues
- Operating and improving our business and services
- Complying with legal and regulatory obligations
App Data collected through our SDK is used for providing Services to our Publisher Partners and for delivering context-based behavioral advertising, which includes the following purposes:
- Providing Services to Publisher Partners
- Troubleshooting technical issues
- Testing and improving our Services
- Identifying users of Publisher Partner applications
- Tracking user interactions
- Providing context-based and behavioral advertising
- Retargeting users with advertising on other applications
- Reporting advertising campaign data to advertisers
If we deidentify your personal information or to the extent that it is anonymized either through aggregation or other means, such information is no longer considered “personal information.” We may use such information for any legal purpose without providing you with additional notice.
How We Share Information
We share and disclose personal information as described below.
We share and disclose Business Data as needed to provide our Services and operate our business. However, we do not “sell” Business Data as defined by the CCPA.
The categories of parties with whom we share Business Data with include:
|IT Service Providers||We share Business Data with our IT service providers as needed to operate our website and business, including with our information technology and web hosting providers.|
|Business Services Providers||We share Business Data with our business services providers, including marketing services, security vendors, contractors, auditors, information services providers, and professional advisors.|
|Corporate Partners||We share Business Data with investors or lenders as part of a transaction involving a merger, acquisition, divestiture, public offering, or similar transaction involving our business.|
|Government and Legal||We share Business Data with third parties as may be required by applicable law, regulation, or legal process.|
In addition to the categories listed above, we share and disclose App Data as needed to provide our Services to Publisher Partners and advertisers. Our sharing of App Data may constitute a “sale” of personal information under the California Consumer Privacy Act (CCPA).
|Advertiser Partners||We may share App Data with our Advertising Partners, including Demand Side Platforms (DSPs), Data Management Platforms (DMPs), and Advertisers as part of our Service.|
|IT Service Providers||We may share AdAdapted IDs with our IT service providers as needed to operate our Services, including with our information technology and web hosting providers.|
|Business Services||We may share AdAdapted IDs with our business services providers, including security vendors, contract developers, auditors, analytics services, and legal and accounting advisors.|
|Corporate Activities||We may share AdAdapted IDs with potential investors or lenders and as part of a transaction involving a merger, acquisition, divestiture, public offering, or similar transaction involving our business.|
|Government and Legal||We may share AdAdapted IDs with third parties as may be required by applicable law, regulation, or legal process.|
California Consumer Privacy Act (CCPA)
Business and Service Provider Roles and Relationships
Under the CCPA, AdAdapted may be a Business, Service Provider, and/or a Third Party with respect to your personal information, depending on the circumstances. If we are responsible for your personal information as a Business or have otherwise been delegated the responsibility as a Service Provider, we will respond directly to your privacy requests.
If we are processing your information as a Service Provider or have received it as a Third Party, you may choose to exercise your data protection rights directly with the Business, such as our Publisher Partners, e.g. the mobile applications that collected your data. Otherwise, if you wish to make your request to us, we will forward your request to the responsible party.
Do Not Sell My Personal Information
In our capacity as a Business and/or Data Broker under the CCPA, AdAdapted sells (and has sold in the preceding 12 months) personal information (e.g. App Data) through our transfer of information to Advertiser Partners and Advertising Networks. In some cases, we combine information with other information as part of such sale.
Privacy Rights of California Residents
If you are a California resident, subject to certain limitations, you have the following rights concerning your personal information:
- Right to Know. You have the right to access the specific pieces of personal information collected about you, the sources from which such information was obtained, the categories of information that have been sold or disclosed for a business purpose, and the commercial purpose for which the information was collected or sold, provided to you in a reasonably portable format if you have a password-protected account.
- Right to Deletion. You have the right to request that we delete any of the personal information we have collected or maintain about you.
- Right to Opt-out of Sales of Personal Information. You have a right to opt-out of the sale of your personal information and to opt-in again at your election.
Exercising Your Rights Under the CCPA
You may exercise your rights by submitting a request to our Data Protection Officer at firstname.lastname@example.org. The CCPA allows for 1 disclosure request per 12-month period at no cost to you. For subsequent requests, we may charge a fee if we determine that the request is excessive, repetitive, or manifestly unfounded, but will not do so without providing you with a cost estimate before processing your request.
If you would like to opt-out of the sale of your personal information, you may opt-out of AdAdapted’s sharing of personal information with third parties by initiating an opt-out request here: Opt-out of AdAdapted.
We respond to and process requests promptly and within the timeframes required by the CCPA. Please note that all requests are subject to proper prior verification before processing as required by the CCPA.
California Data Broker Registration
AdAdapted has registered as a data broker with the California Attorney General. Accordingly, California residents may exercise their right to opt-out of our sale of their personal information here: Opt-out of AdAdapted.
Data Retention and Disposal
- Business Data are retained for as long as may be necessary for the purposes for which it was obtained, including any possible follow ups, to the extent that such information is not subject to a lawful request for deletion. We may also retain Business Data for a reasonable time after its collection to ensure the integrity of log files, prevent fraud and spoofing, and protect the security of our Services.
- App Data are retained for as long as is required to provide our Services to the extent that such information is not subject to a lawful request for deletion.
Exercising Control Over Your Privacy
We provide several ways to exercise control over your privacy.
California residents may opt-out of our sale of your personal information here: Opt-out of AdAdapted. You may also exercise your applicable rights by contacting us at email@example.com. All privacy requests are subject to proper prior verification and fulfilled to the extent that the law may require.
Cookie Notice and “Do Not Track” Requests
The following applies only to our website located at www.adadapted.com:
Other types of cookies include performance and targeting cookies. Performance cookies are used for analytical purposes. For example, we use Google Analytics to collect and measure visits and traffic to our website. You can learn how Google uses such data here: www.google.com/policies/privacy/partners. Targeting cookies may be used to present you with customized content or interest-based advertising by our partners. In such cases, the privacy policies of these third parties, including Google, will also govern the use of your personal information.
Under the California Online Privacy Protection Act (CalOPPA), we want to inform you about our “Do Not Track” (“DNT”) request policy. DNT is a feature that some web browsers offer to allow users to send signals to websites so that no information about their browser session will be shared. You may enable your web browser to send to our website a DNT request. However, this action may degrade your user experience. You can learn more about DNT here: https://www.eff.org/issues/do-not-track
Under the Children’s Online Privacy Protection Act (“COPPA”) and other laws, our website and associated services are not marketed to children under sixteen (16) years of age. We do not intentionally collect information from children. We encourage parents and guardians to take appropriate steps to ensure the safety and privacy of their children online.
Direct Marketing Data
Under California’s “Shine the Light” law, we do not disclose the defined types of personal information to third parties for their direct marketing purposes.
We work hard to protect personal information through commercially reasonable and appropriate security measures. Our efforts include utilizing encryption and physical, technical, and administrative controls to prevent the unauthorized access and disclosure of personal information. However, we encourage all users to exercise due care when interacting with our website and services, just as one would with any other website.
Good personal security hygiene can help protect you online, including using a unique and complex password and not sharing or allowing others to access your account. Be sure to connect to our website and services over secure networks, log out after using our service, and stay alert to unusual or suspicious activities, including phishing emails.
AdAdapted will never ask you for a password. If needed to verify your identity in responding to privacy requests, we may ask you for other personal information to confirm your identity.
If any of the personal information we retain about you is the subject of a breach of personal information under applicable law, we will take appropriate actions, including providing you with notice of such breach, as such law or laws may require.
How to Contact Us
AdAdapted Privacy Office
206 East Huron Street, Suite #101
Ann Arbor, MI 48104
Last Updated: 03/01/2021