December 1, 2016

AdAdapted Privacy Policy

Privacy Policy

Effective: February 9, 2021

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. 

This Privacy Policy provides transparency about our privacy practices, including how we collect, use, and disclose personal information, and how you can exercise your applicable privacy rights. The actual administration of privacy rights may vary based on your individual circumstances and the laws applicable to you, or as AdAdapted may otherwise offer to facilitate in its sole discretion and without obligation. 

Scope and Applicability

This Privacy Policy applies to our Services, wherever operated, as well as to information collected through our sales and marketing website at www.AdAdapted.com.

Our relationship with you determines how this Privacy Policy applies to your information.  For example, as a user of our website, we may collect certain personal information as part of that interaction. In other circumstances, we may process your information as a “Service Provider” or “Third Party” to our Publisher Partners. In such cases, the privacy policy of our Publisher Partners may apply in addition to certain portions of our privacy policy. If you have any question as to who is responsible for your information, please contact us at privacy@AdAdapted.com

Information We Collect and Receive

AdAdapted may collect certain personal information directly or indirectly based on your specific relationship with us. 

AdAdapted.com Users:

We collect or receive the following categories of personal information (“Business Data”) from your use of our website and your related interactions with us:

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:

Our Uses of Personal Information

Our use of personal information depends on the type of information and is limited to the purposes described in this Privacy Policy (or through other applicable notice) and any other purpose that you may intend or direct through your interactions with us. 

Business Data

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

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. 

Business Data

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:

App Data

In addition to the categories listed above, we share and disclosure 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). 

California Consumer Privacy Act (CCPA)

The following provisions apply only to California residents as defined by the CCPA and supplement our broader Privacy Policy:

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 to 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 privacy@AdAdapted.com or (313) 744-3383. 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

We retain and dispose of personal information according to our data retention and disposal policies, which are designed to meet the requirements of applicable law. Generally, this means:

  • 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. 

As part of our backup and recovery policies, deleted data may remain in our possession for an additional period in the form of secure backups. 

Data may also be retained as part of legal and regulatory record-keeping obligations, such as to maintain records of privacy requests. 

  

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 privacy@AdAdapted.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:  

We use cookies on our website for various purposes, including to measure user interactions and personalize your user experience. When accessing our site, you may be presented with the opportunity to opt-in or opt-out of certain types cookies, not including essential cookies, which are necessary for the operation of the site. 

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

Children’s Data

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. 

Unsubscribe

If you wish to unsubscribe from AdAdapted’s sales and marketing emails, please follow this link: www.hubspot.com

Information Security

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. 

Breach Notification

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. 

Changes to This Privacy Policy

We may update this Privacy Policy from time-to-time. If we make any revisions to this Privacy Policy, we will revise the “Last Updated” date below. If such changes represent material differences in the purposes for which your personal information was originally obtained, we will provide you with additional notice and request that you consent to such changes. Notice may be provided by adding a statement to the main website page or by sending you an email or other notification, as may be appropriate to the circumstances.

How to Contact Us

For inquiries about this Privacy Policy or to make a request or file a complaint, please contact us at the information below:

AdAdapted Privacy Office
206 East Huron Street, Suite 101
Ann Arbor, Michigan 48104
United States
Phone: (313) 744-3383
Email: privacy@AdAdapted.com 

This Privacy Notice was Last Updated: February 9, 2021, at 09:02 UTC.

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