Privacy policy

All or N including all of its affiliates respects your privacy and is committed to protecting it through our compliance with this policy. With this privacy policy, we would like to inform you how we process your personal data.

The responsible body according to art. 4 European General DataProtection Regulation (“GDPR”) is All or N, Oakway Lane Str.153, Los Angeles, California(CA), 90017, managing director is Sheila E Dejean.

In case of any questions relating to data protection, please get in touch with us at [email protected].

Our external Data Protection Officer is ePrivacy GmbH, represented by Prof. Dr. Christoph Bauer, Große Bleichen 21, 20354 Hamburg. If you wish to communicate directly with our Data Protection Officer (because you have a particularly sensitive matter for example), please send your request to them by post. Please state in your request that your concern relates to the company Adjust GmbH.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. This policy may change from time to time (see Changes to our Privacy Policy). If you are a California resident, please also review our California Resident Privacy Notice (“CCPA”).

Collection and Use of Data

Content

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.

Intended Use

We base the processing of your data on the following legal bases:

Your consent, if you have given us such consent (Art. 6 para. 1 lit. a) GDPR), The initiation or execution of a contract with you (Art. 6 para. 1 lit. b) GDPR), The fulfilment of legal obligations (Art. 6 para. 1 lit. c) GDPR), The implementation of our legitimate interests (Art. 6 para. 1 lit. f) GDPR)

When processing your data, we pursue the following legitimate interests:

To present and improve our website To estimate the size of our target group and their user pattern To save information about your preferences so that we may adapt our website to your individual interests To speed up your search To recognize you when you return to our website

Furthermore, with this information we will be able to ensure the stability and security of our website.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

To present our Website and its contents to you To provide you with information, products or services that you request from us To fulfill any other purpose for which you provide it To target audience and for marketing purposes To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection To notify you about changes to our Website or any products or services we offer or provide through it and to help us understand how the Website is being used In any other way we may describe when you provide the 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.

Information We Collect About You

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:

Traffic data Location Server logs Resources on our website which you access and use IP address, operating system and browser type and information which is collected through cookies, web-beacons and other tracking technologies.

Furthermore, we are processing 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. Keep in mind that we also handle correspondence and process data to that respect.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). We, and businesses we work with, require for some features of our website. Cookies are small files that your browser places on your device in a designated directory. These cookies can be used to determine, for example, whether you have visited a website before. They are deleted after the end of your visit. Other cookies (“persistent cookies”) are automatically deleted after a specified period, which may vary depending on the cookie. You can delete cookies at any time in the security settings of your browser and object to the use of cookies through your browser settings. Please note that disabling cookies may result in restrictions when using our website. Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit All or N, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). Log files. Every time you access our Internet pages, your usage data is transmitted through the respective internet browser and stored in log files, the so-called server log files. The records stored in this case contain the following data: domain and location from which the user is accessing the website.

The information we collect on or through our Website may include:

Information that you provide by filling in forms on our Website. This includes information provided at the time of subscribing to our newsletter, subscribing to our service, or requesting further services. We may also ask you for information when you report a problem with our Website or the All or N technology. Records and copies of your correspondence (including e-mail addresses), if you contact us Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website Details of Website searches and button clicks are also recorded.

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.

Third-party Use of Cookies and Other Tracking Technologies

Some third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

Requirement or Obligation to Provide Data

Unless this is expressly stated, the provision of your data is not required or obligatory.

Duration of Retention of Data

We store your data:

If you have consented to the processing at the latest until you revoke your consent If we need the data to carry out a contract at most as long as the contractual relationship with you or statutory retention periods are running If we use the data on the basis of a legitimate interest at most as long as your interest in deletion or anonymization does not prevail.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

To our subsidiaries and affiliates for the sole purpose of providing our services. To contractors, service providers and other third parties we use to support our business: Provider of web analysis tools Web hosting and web development providers Marketing and advertising service providers E-mail and newsletter provider Service provider for editing and translations CRM system service provider Cloud services Payment service provider, Conference and Webinar Software Service provider for online surveys Service provider for chat software Social media platforms To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of All or N assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by All or N about our Website users is among the assets transferred. To fulfill the purpose for which you provide it. For any other purpose disclosed by us when you provide the information. With your consent.

We may also disclose your personal information:

To comply with any court order, law or legal process, including to respond to any government or regulatory request To enforce or apply our terms of use and other agreements, including for billing and collection purposes If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Adjust, our customers or others

Unless otherwise stated herein, your personal data will be processed on our servers. If we have commissioned technical service providers, they will only process the data after having received express instructions and they are contractually obliged to guarantee adequate technical and organizational measures for data protection. Insofar as we refer to integrated services of other providers in this privacy policy, it can be assumed that personal data will be transmitted to the specified headquarters of these providers. These providers may be based in a so-called third country outside the European Economic Area.

Choices About How We Use and Disclose Your Information

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:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website may then be inaccessible or not function properly Opt-out. You may “opt out” of receiving marketing or promotional emails from us by following the instructions in those emails. If you opt out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

How we protect Your Data

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. All transactions, regardless of their nature, are encrypted using SSL technology The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website. Transfer between subsidiaries: We may transfer user and customer information to our affiliates and to third party providers for the sole purpose of providing our services.

Newsletter

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.

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 protected].

Transfer to Third Countries

If personal data is being transferred to countries outside the European Economic Area, we only transfer it to third countries where the EU Commission has confirmed an adequate level of protection or where we can ensure the careful handling of personal data by means of contractual agreements or other suitable guarantees, such as certifications or proven compliance with international security standards.

In compliance with the Privacy Shield Principles, we are committed 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 us at: [email protected]

Cookies are set with your consent, which you can revoke at any time with effect for the future via consent management tool. When using the service, a transfer of your data to the USA cannot be excluded. Please note the information in the section “Data transfer to third countries”.

Google Remarketing

We also use the Google Analytics advertising features (remarketing). This function enables us, in conjunction with the cross-device functions of Google, to display advertisements in a more targeted manner and to present users with ads that are tailored to their interests. Via the remarketing, users are shown ads and products for which interest has been identified on other websites in the Google network. The function allows us to link advertising target groups created via Google Analytics Remarketing with the cross-device functions of Google Ads. In this way, interest-based, personalized advertising messages that have been adapted to a user depending on previous usage and surfing behavior on an end device (e.g. cell phone) can also be displayed on another end device of the user (e.g. tablet or PC).

If you have given your consent, Google will link your web and app browsing history with your Google account for this purpose. In this way, the same personalized advertising messages can be placed on every end device on which you log in with your Google account. The aggregation of the collected data in your Google account is based solely on your consent, which you can give or revoke at Google. For these linked services, data is then collected via Google Analytics for advertising purposes. To support the remarketing function, Google Analytics collects users’ Google-authenticated IDs, which are temporarily linked to our Google Analytics data. This is used to define and create target groups for cross-device ad advertising.

Meta Pixel (formerly known as Facebook Pixel)

We use the “visitor action pixels” from Meta Platforms Inc. (“Meta”) on our website. This allows user behavior to be tracked.