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Privacy Policy

 LAST UPDATED: May 27th, 2022

Our Commercial Activities

AdLibertas provides tools and services to our customers, mobile app developers (“Customers”), so they can track and analyze mobile app end user (“User”) actions in the context of mobile app measurement.

AdLibertas, Inc. is concerned about privacy issues and wants you to be familiar with how we collect, use and disclose information.

  • The first section of our policy outlines our compliance policies for both Customers and Users in relation to privacy regulations and privacy acts as well as opt-out policies and instructions.
  • The second section describes information we collect in the course of providing services to our customers (the “Services”).
  • The third section of this document describes our practices in connection with information that we collect directly from our Customers – the App Developers — through the websites operated by us.

SECTION 1 – COMPLIANCE

European Union’s General Data Protection Regulation (the “GDPR”) and the United Kingdom’s Data Protection Act (the “UKDPA”)

AdLibertas provides tools and services to mobile app developers (“Customers”) so that they can track and analyze certain User actions in the context of mobile app measurement. AdLibertas does not collect any User data directly (except from Customers outlined in section three below). With regard to AdLibertas’ Services, under the EU’s General Data Protection Regulation (the “GDPR”) and the UK’s Data Protection Act (the “UKDPA”), AdLibertas is a data processor. As a data processor, AdLibertas processes, and may store, information sent by AdLibertas customers from their mobile apps. AdLibertas’ Customers may send information about the User of their apps, and the users’ devices, to AdLibertas for processing and storage. Our Customers– the mobile app developers– must receive User consent in order for AdLibertas to process, and perhaps store, data. AdLibertas recognizes the right of access under Section 15 of GDPR and Section 45 of UKDPA.

If you are a User of an AdLibertas customer’s mobile app, and you wish to exercise your right of access, you must contact the owner or operator of the mobile app (the data collector). AdLibertas will cooperate with Customers to support and comply with any such data subject rights requests.

AdLibertas commits to resolve complaints about your privacy and our collection or use of your personal information. European Union, United Kingdom, or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact AdLibertas at: privacy@adlibertas.com.

 

California Consumer Privacy Act (CCPA)

With regard to AdLibertas’ Services, under CCPA, AdLibertas is a service provider. As a service provider, AdLibertas processes, and may store, information sent by AdLibertas Customers from their mobile apps. AdLibertas’ customers may send information about the Users of their apps, and the User devices, to AdLibertas for processing and storage. AdLibertas Customers must comply with the opt-out requirements under CCPA (Cal. Civ. Code § 1798.120(a)) and take into account any exceptions or other requirements mandated by law. As a service provider, AdLibertas relies on CCPA’s business purpose exemption under Cal. Civ. Code § 1798.140(t)(2)(C) and as a service provider, AdLibertas does not have any direct obligations to the Users to obtain consent, provide opt-outs, or delete data. If you are a User of an AdLibertas customer’s mobile app and you wish to opt-out or exercise another right under CCPA, you must contact the app publisher (the business).

AdLibertas will cooperate with Customers to support and comply with any such data subject rights requests.

The above applies to both Section 2 and Section 3 below.

 

SECTION 2 –  SERVICES PRIVACY POLICY

CUSTOMER DATA

Our Customers are app developers and app publishers. AdLibertas collects and combines reporting from 3rd parties to provide novel analytics that enable our Customers to better understand aspects of their app. There are 3 main categories of data (“Customer Data”) we access in the context of our services:

  • Advertising data: We access the impressions, clicks and revenue as reported by 3rd party ad providers, for the purposes of attributing an App Developer’s ad revenue. For example, AdID 12345 generated $1 in ad revenue yesterday.
  • App Store transaction data: We access the in-app purchase and subscription metrics as reported by the iTunes and Google Play app stores, for the purposes of attributing an App Developer’s app store-managed revenue. For example, vendorID 12345 purchased a 1-year subscription yesterday.
  • App usage data: We access the app usage data for the purposes of attributing usage and with advertising data and app store transaction data. For example, VendorID 12345 played 4 games and saw 3 ads yesterday.

The list above is not exhaustive and because AdLibertas is not actively involved in the collection of any Customer Data from Users, collected Customer Data may vary. User consent is managed directly by our Customer, the mobile app developer. AdLibertas cooperates with Customers to support and comply with any such User Data subject rights and requests. For more information on how this data is being collected, please refer to the Privacy Policies of the App Developer in question.

 

HOW WE COLLECT CUSTOMER DATA

We collect Customer Data through APIs of various third party services made available by our Customers.

 

HOW WE USE CUSTOMER DATA

We use Customer Data to provide the Services to the relevant customer. We may also use it to improve the Services and develop new products and services.

We do not share Customer Data with any Customer other than the Customer to which it relates, unless we have received the prior express written consent of the customer to do otherwise. Without consent, we may disclose Customer Data:

To our affiliated and third-party service providers; and To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

In addition, we may use or disclose Customer Data as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Unless prohibited by applicable law or advertising network terms, we may aggregate Customer Data such that it is not reasonably identifiable with or to the customer to which it relates, or the customer’s Users (“Aggregate Data”). We may share Aggregate Data with third parties for industry research and analysis, demographic profiling and other similar purposes.

 

HOW WE COLLECT AND PROCESS CUSTOMER DATA FOR CUSTOMERS

Customers may send information about individuals using their app (“Users”) to AdLibertas for processing and storage. This information may include Vendor ID (if available), IP address, Apple Search attribution (if enabled), Bundle ID, SDK Version, App Version, OS Version, Device Type, Device Model, Device Locale, Device Country, OS Platform, Limit Ad Tracking setting, and Advertising ID. Advertising IDs are user-specific, unique character strings that can be reset by the user and are used to track a User’s device for advertising purposes. Examples include Google Ad ID and IDFA.

AdLibertas Customers must abide by all applicable laws and obtain all applicable consents before sending Customer Data to AdLibertas. If you feel that your data has been collected by an AdLibertas Customer without your consent, please contact the AdLibertas Customer directly. If you would like to access, modify or delete your data collected by an AdLibertas Customer, please contact the AdLibertas Customer directly.

AdLibertas also recognizes the Right to Erasure under Article 17 of GDPR. For erasure requests, since AdLibertas is a data processor, please contact the AdLibertas Customer directly with your deletion request.

AdLibertas cooperates with Customers to support and comply with any such User Data subject rights and requests.

 

HOW WE PROCESS AND SECURE DATA

AdLibertas is a SaaS company whose solutions are built on the AWS platform. Customer Data is processed by AdLibertas in secure locations operated by Amazon (AWS) in the United States.

AdLibertas uses appropriate and reasonable measures to protect data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, while taking into account any inherent risks and the nature of the data. Additional details on AWS security certifications and procedures can be found here: https://d1.awsstatic.com/whitepapers/Security/AWS_Security_Whitepaper.pdf.

 

SECTION 3: WEBSITE PRIVACY POLICY

This section outlines privacy policies we employ to AdLibertas Customers (or potential Customers) on the AdLibertas Websites.

Personal Information

“Personal Information” is information that identifies an AdLibertas Customer as an individual or relates to an identifiable person. We collect Personal Information, such as name, organization name, physical address and email address, from our customers and potential customers when they provide it to us through the Services (such as by creating an account), through the Website, or via email sent to a AdLibertas email address.

How We May Use Personal Information

We may use Personal Information:

  • To respond to your inquiries and fulfill your requests.
  • To send administrative information to you, such as information regarding our services and changes to our terms, conditions and policies.
  • To provide you with customer service.
  • To send you marketing communications that we believe may be of interest to you.
  • For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
  • As we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Your Personal Information may be disclosed:

  • To our affiliated and third-party service providers and consultants who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services.
  • To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
  • As we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

OTHER INFORMATION

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as browser and device information; information collected through cookies, pixel tags and other technologies; and aggregated information.

How We May Collect Other Information

We and our third party service providers may collect Other Information in a variety of ways, including:

  • Using cookies: Cookies are pieces of information stored directly on the device that you are using to access the Websites. Cookies allow us to collect information such as browser type, time spent on the Websites, pages visited and other anonymous traffic data. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. Please note, however, that if you don’t accept Cookies, you may not be able to access all portions or features of the Websites. Some third-party services providers that we engage (including third-party advertisers) may also place their own Cookies on your hard drive. Note that this Privacy Policy covers only our use of Cookies and does not include use of Cookies by such third parties.
  • Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with the Websites to, among other things, track the actions of users (including email recipients), measure the success of our marketing campaigns and compile statistics about use of the Websites.
  • Using a third-party analytics provider: We use Google Analytics and Lucky Orange for our Website analytics. These providers use cookies and similar technologies to analyze how users use the Websites, compile statistical reports on Website activity, and provide other services related to the Websites. They may also collect information about Website visitors’ use of other websites. For more information about Google Analytics, including how to opt out, please go to: https://tools.google.com/dlpage/gaoptout. For more information on Lucky Orange privacy practices, please go to: https://www.luckyorange.com/legal/privacy.
  • IP Address: Your IP Address is a number that is automatically assigned to your computer by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever a user accesses the Websites, along with the time of the visit and the page(s) visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other services. We use IP Addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Websites.
  • By aggregating information: Aggregated Personal Information does not personally identify you (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).

How We May Use and Disclose Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use it for all the purposes for which we use and disclose Personal Information. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

THIRD PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Websites link. The inclusion of a link on the Websites does not imply endorsement of the linked site or service by us or by our affiliates.

SECURITY

We take reasonable administrative, physical and electronic measures designed to protect Personal Information and Other Information from unauthorized access, use or disclosure. Data collected from your device is encrypted using SSL or other technologies. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.

CROSS-BORDER TRANSFER

The Websites are controlled and operated by us from the United States, and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Websites you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.

MODIFYING INFORMATION

Customers can access and modify their billing address by emailing privacy@adlibertas.com. If customers want to delete their own Customer Data or their Account from the Services, customers can contact us at privacy@adlibertas.com with a request. We will delete the Customer Data but some information may remain in archived/backup copies for our records or as otherwise required by law. If a customer ceases subscribing to the Services, please email privacy@adlibertas.com and we’ll automatically delete the customer’s Account and take steps to delete that customer’s Customer Data from the Services.

UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy. The “Last Updated” legend at the top of this page indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Websites. Your use of the Websites following these changes means that you accept the revised Privacy Policy.

CONTACTING US

If you have any questions about this Privacy Policy, please contact us at privacy@adlibertas.com

QUESTIONS

Please contact us at privacy@adlibertas.com if you have any questions about our Privacy Policy or AdLibertas’s compliance with GDPR or CCPA. Please email privacy@adlibertas.com if you would like to contact AdLibertas’s Data Protection Officer (DPO), or EU representative under GDPR Article 27.