Privacy Policy

Effective: January 1, 2023

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 services. This information allows us to deliver relevant advertising to mobile grocery shoppers on the mobile applications of our app publisher partners (“Publisher Partners”). We take seriously our responsibility to facilitate privacy rights fairly under applicable law.

This Privacy Policy serves as notice of our collection of personal information and 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 in its sole discretion and without obligation.

Certain portions of this Privacy Policy apply only to residents of the state of California, Virginia, Connecticut, Colorado, and Utah, and to certain Canadian residents, as set forth below.

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SCOPE AND APPLICABILITY

Except as otherwise indicated, this Privacy Policy applies to personal information we collect in all circumstances addressed herein, including personal information collected through our marketing website at https://www.adadapted.com/, and through our Publisher Partners, as described below.

Our relationship with you determines how this Privacy Policy applies to your information. Where we collect your personal information through our Publisher Partners, the privacy policies of our Publisher Partners may also 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.

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INFORMATION WE COLLECT AND RECEIVE

We may collect or obtain certain personal information directly or indirectly from you based on your relationship with us, or from third parties.

Business Contacts / Job Applicants

We may collect or obtain the following categories of personal information (“Business Data”) from your use of our website and your other interactions with us, including applying for a job:

Publisher Partner App Users

We may collect or obtain certain personal information (“App Data”) from our Publisher Partners through our Software Development Kit (SDK) within our Publisher Partners’ mobile applications:

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HOW WE USE PERSONAL INFORMATION

Our use of personal information 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.

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Business Data

We use Business Data for providing our services and operating our business, including 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
Evaluating employment and internship applications
Complying with legal and regulatory obligations

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App Data

We use App Data collected or obtained through our SDK for providing services to our Publisher Partners and for delivering relevant advertising for our Advertising Partners, including 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 relevant advertising
Serving advertisements to users on other applications
Reporting aggregated and de-identified advertising campaign data to advertisers

De-identified information is no longer considered “personal information.” We may use such information for any legal purpose without providing you with additional notice.

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HOW WE DISCLOSE PERSONAL INFORMATION

We disclose personal information as described below.

Business Data

We share and disclose Business Data as needed to provide our services and operate our business. We may disclose Business Data to the following categories of third parties:

App Data

We disclose App Data as needed to provide our services and operate our business. We disclose App Data to the following categories of third parties:

PRIVACY RIGHTS OF U.S. STATE RESIDENTS

To the extent each such law is in effect and may apply, residents of the U.S. states of Virginia, Connecticut, Colorado, and Utah may have may have certain privacy rights, including:

Access and Portability. You may have the right to request access to the personal information we maintain about you and to receive that information in a portable format.
Correction. You may have the right to request that we correct inaccuracies in the personal information we maintain about you.
Deletion. You may have the right to request that we delete the personal information we maintain about you.
Opt-out of Sale of Personal Information, Targeted Advertising, and Profiling. You may have the right to opt-out of the sale of your personal information, targeted advertising, and profiling.
Consent or Opt-in to the Collection of Sensitive Personal Information. You may have the right to consent or opt-in to the collection and use of your sensitive personal information.
Automated Decision-making. You may have the right to request to opt-out of certain types of automated decision-making, subject to certain exceptions.
Non-discrimination. You may have the right to not be discriminated against in the event you exercise your applicable privacy rights listed above. If you exercise such rights, you will not be denied goods or services, charged a higher rate, or provided with lower quality products.

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Exercising your rights under applicable U.S. state privacy laws

You, or an authorized agent, may exercise your rights by submitting a request to our Privacy Office at privacy@adadapted.com. We allow the number of disclosure requests per 12-month period as required by applicable law. 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.

We respond to and process requests within the timeframes required by applicable law. Please note that all requests are subject to proper prior verification before processing as may be required by applicable law.

If you are the authorized agent of an individual, you may have to take additional steps to verify your identity and demonstrate that you can exercise that person’s rights on their behalf.

‍Sale of personal information, targeted advertising, and profiling

As defined by applicable law, we may “sell” or use the personal information of Publisher Partner App Users for targeted advertising and profiling, including in the preceding 12-months.

Opt-out of the sale of your personal information, targeted advertising, or profiling

Eligible U.S. state residents may opt-out of targeted advertising and/or the sale of their personal information here: Opt-out of AdAdapted or by contacting us at privacy@adadapted.com.

Please note that opt-out choices may only apply to the specific web browser or instance of the mobile application to which the opt-out has been requested. Generally, opt-out choices are linked to your mobile device ID (e.g., Apple IDFA).

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PRIVACY RIGHTS OF CALIFORNIA RESIDENTS

The following apply only to residents of the state of California:

California Consumer Privacy Rights

Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CPRA”), and its implementing regulations, consumers who are residents of the state of California may have the following privacy rights:

Right to Know. You may have the right to request 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.
Deletion. You have the right to request that we delete the personal information we have collected or maintain about you.
Correction. You have the right to request that we correct inaccuracies in the personal information we maintain about you.
Opt-out of the Sale and Sharing of Personal Information. You have a right to opt-out of the “sale” of your personal information the “sharing” of your personal information for purposes of cross-context behavioral advertising, and to opt-in again at your election.
Limit the Use and Disclosure of Sensitive Personal Information. You may have the right to request that we limit the use and disclosure of your sensitive personal information.
Restrict Profiling. You may have the right to request that we restrict the use of your personal information for the purposes of profiling.
Portability. You may have the right to obtain a copy of certain Personal Information in portable (e.g., machine readable) format.
Opt-out of Automated Decision-making. You may have the right to opt-out of certain types of automated decision-making, subject to certain exceptions.
Non-Discrimination. You may have the right to not be discriminated against in the event you exercise your rights listed above. If you exercise such rights, you will not be denied goods or services, charged a higher rate, or provided with lower quality products.

‍Exercising your rights under the CPRA

You, or an authorized agent, may exercise your rights by submitting a request to our Privacy Office at privacy@adapted.com or by completing our webform available at https://www.adadapted.com/legal/do-not-sell.

Unless otherwise required by law, we will allow two disclosure requests 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.

We respond to legitimate privacy requests within 10 days of receipt and process requests within 45 days unless there is cause for an extension. Except with respect to requests to opt-out of the sale or sharing of personal information, all privacy requests are subject to proper prior verification before processing. Typically, this means you will be required to verify certain pieces of information we maintain about you.

If you are the authorized agent of an individual making a request, you may have to take additional steps to verify your identity and demonstrate that you can exercise the individual’s rights on their behalf.

Sale and sharing of personal information

As defined by the CPRA, we may “sell” or “share,” and we may have sold or shared in the preceding 12-months, any category of personal information collected from Publisher Partner App Users, including the following types of personal information:

Identifiers such unique personal identifier, online identifier, Internet Protocol address, or other similar identifiers
Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
Internet or other electronic network activity information, including, but not limited to, information regarding a consumer’s interaction with an internet website application, or advertisement
Inferences drawn from any category of personal information to create a profile about a consumer reflecting the consumer’s preferences, predispositions, and behavior

We have sold or shared the above personal information with:

Advertising Partners, including Demand Side Platforms (DSPs), Data Management Platforms (DMPs), and Advertisers

We have sold or shared your personal information for the following business or commercial purposes:

Delivering targeted native advertising campaigns to mobile grocery shoppers as part of our service to our Publisher Partners and Advertising Partners

We have not sold or shared, including in the preceding 12-months, any category of personal information collected from Business Contacts / Job Applicants.

Do Not Sell or Share My Personal Information

Exercise the right to opt-out of the sale and sharing of your personal information:

California consumers may opt-out the sale and sharing of their personal information here: Opt-out of AdAdapted or by contacting us at privacy@adadapted.com.

Opt-out preference signals

We currently do not accept opt-out preference signals from any platform, technology, or mechanism (e.g., web browsers).

CPRA Definitions:

As used in this Section:

“Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, except as may be lawfully available public information.

“Sensitive personal information” means Personal information that reveals (a) social security, driver’s license, state identification card, or passport number; (b) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) precise geolocation; (d) racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of mail, email, and text messages unless the company is the intended recipient of the communication; (f) genetic data; and any (g) biometric information processed for the purpose of unique identification; (h) personal information collected and analyzed concerning health; and personal information collected and analyzed concerning sex life or sexual orientation.

CPRA categories of personal information we collect

We may collect, and may have collected in the preceding 12-months, the following categories of personal information about Business Contacts / Job Applicants and App Publisher Partner Users, including the sources of such information:

CPRA categories of sensitive personal information

We may collect, and may have collected in the preceding 12-months, the following categories of sensitive personal information about Business Contacts / Job Applicants, including the sources of such information:

CPRA business and commercial purposes

We may collect, and may have collected in the preceding 12-months, personal information for the following business or commercial purposes:

CPRA categories of personal information disclosed to third parties for a business purpose

We may disclose, and may have disclosed in the preceding 12-months, personal information to the following third parties for the following business purposes:

Retention period or criteria

AdAdapted retains personal information for a period commensurate with the purposes for which it was collected or obtained. Please see our retention notice below for further information.

Personal information of minors

AdAdapted has no actual knowledge that it sells or shares the personal information of persons under sixteen (16) years of age.

Do not track

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 our website a DNT request. However, our website may not respond to DNT requests and this action may degrade your user experience. You can learn more about DNT here: https://www.eff.org/issues/do-not-track

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PRIVACY RIGHTS OF CANADIAN RESIDENTS

Under Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”) and the Provincial Privacy Acts (together, the “Canadian Privacy Laws”), and their respective amendments and implementing regulations, Canadian residents are afforded certain privacy rights. If you are a Canadian resident, subject to certain limitations, you may have the following rights concerning your personal information:

Openness and Transparency. You may have the right to know the personal information we collect about you and the purposes for its collection.
Access. You may have the right to access personal information we maintain about you, subject to certain exceptions.
Correction. You may have the right to correct inaccuracies in personal information we maintain about you.
Deletion. You may have the right to request that we delete personal information we have collected or maintain about you.
De-indexing. You may have the right to request your personal information be “de-indexed” from certain types of distribution.
Withdraw Consent. You may have the right to withdraw consent to our use of your personal information, subject to certain exceptions.

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Exercising Your Rights Under the Canadian Privacy Laws

You, or an authorized agent, may exercise your rights by submitting a request to privacy@adadapted.com.

We respond to and process requests promptly and within the timeframes required by the Canadian Privacy Laws. Please note that all requests are subject to proper prior verification before processing.

Transfer of Canadian Personal Information

Your personal information may be transferred to third countries where an adequate level of data protection can be ensured. By sharing Personal Information with us, you consent to the transfer of your personal information to such third countries.

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DATA RETENTION

Subject to a lawful deletion request, we retain personal information commensurate with the purposes for which it was collected or obtained, which retention periods 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 collected or obtained and any other lawful purpose (e.g., protecting the security of our services and compliance purposes). We may also retain Business Data for an additional time in the form of data backups and archives.
App Data are retained for as long as may be required to provide our services and any other lawful purpose (e.g., protecting the security of our services and compliance purposes). We may also retain App Data for an additional time in the form of data backups and archives.

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COOKIE NOTICE

The following applies only to our website located at https://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: http://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, also govern the use of your personal information.

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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 personal information from persons under sixteen (16) years of age. We encourage parents and guardians to take appropriate steps to ensure the safety and privacy of their children online.

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DIRECT MARKETING

Under California’s “Shine the Light” law, we do not disclose the applicable types of personal information to third parties for their direct marketing purposes.

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UNSUBSCRIBE

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

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DATA BROKER REGISTRATION

AdAdapted has registered as a data broker with the applicable California and Vermont data broker authorities. Accordingly, California and Vermont residents may exercise their right to opt-out of the sale of their personal information here: Opt-out of AdAdapted.

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INFORMATION SECURITY

We take reasonable and appropriate measures to protect the security of your personal information. However, we encourage you to always exercise due care when interacting with our website and services.

AdAdapted will never ask you for a password. We may ask you for other (non-sensitive) personal information if needed to verify your identity in responding to privacy requests.

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CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically. If we make any material revisions to this Privacy Policy, we will revise the “Last Updated” date below. If required by applicable law, we may provide you with additional notice, as necessary.

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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, MI 48104
United States
Email: privacy@adadapted.com

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