Adapty privacy policy

This Privacy Policy explains what personal data is collected when you visit or use the website located at: https://adapty.io/ (the “Website”), the services and products provided through it (together with the Website, the “Service”), how such personal data will be processed.

Adapty Tech Inc., a company registered under the laws of the state of Delaware, having its registered office at 2093 Philadelphia Pike #9181 Claymont, DE 19703, USA will be the controller of your personal data.

We collect data you give us voluntarily (for example, email address, payment details, contact details, such as phone number, country, company name, and your position). We also collect data automatically (for example, your IP address, information about your device, and unique identifiers of your device such as IDFA, AAID, IDFV, UUID).

We process your personal data:

This includes enabling you to use the Website and Service in a seamless manner and preventing or addressing Service errors or technical issues.

We process your personal data to respond to your requests for technical support, Service information, or to any other communication you initiate. For this purpose, we may send you, for example, notifications or emails about, the performance of our Service, security, payment transactions, notices regarding our Terms of Service, or this Privacy Policy.

We communicate with you, for example, by push notifications or by email. These may include reminders or other information about the Service. As a result, you will, for example, receive a push notification that a new feature has been deployed in the Service. To opt out of receiving push notifications, you need to change the settings on your device. To opt out of receiving emails, you should click the unsubscribe link in the footer of each email.

This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what categories of users use our Services. As a consequence, we often decide how to improve the Service based on the results obtained from this processing.

We process your personal data for our marketing campaigns. As a result, you will receive information about our products, such as, for example, special offers or new features and products available on the Service. We may show you advertisements on our Service, and send you emails for marketing purposes. If you do not want to receive marketing emails from us, you can unsubscribe by following the instructions in the footer of the marketing emails.

We and our partners use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you visited our Website, you might see ads of our products in your Facebook feed.

How to opt out or influence personalized advertising

iOS: On your iPhone or iPad, go to Settings > Privacy > Apple Advertising and deselect Personalized Ads. 

Android: To opt out of ads on an Android device, go to Settings > Privacy > Ads and enable Opt out of Ads personalization. In addition, you can reset your advertising identifier in the same section (this also may help you to see less of personalized ads). To learn even more about how to affect advertising choices on various devices, please look at the information available here.

macOS: On your MacBook, you can disable personalized ads: go to System Preferences > Security & Privacy > Privacy, select Apple Advertising, and deselect Personalized Ads.

Windows: On your laptop running Windows 10, you shall select Start > Settings > Privacy and then turn off the setting for Let apps use advertising ID to make ads more interesting to you based on your app activity. If you have other Windows versions, please follow the steps here

To learn even more about how to affect advertising choices on various devices, please look at the information available here.

In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links:

• Network Advertising Initiative – http://optout.networkadvertising.org;
• Digital Advertising Alliance – http://optout.aboutads.info;
• Digital Advertising Alliance (Canada) – http://youradchoices.ca/choices;
• Digital Advertising Alliance (EU) – http://www.youronlinechoices.com;
• DAA AppChoices page – http://www.aboutads.info/appchoices.

Browsers: It is also may be possible to stop your browser from accepting cookies altogether by changing your browser’s cookie settings. You can usually find these settings in the “options” or “preferences” menu of your browser. The following links may be helpful, or you can use the “Help” option in your browser.

• Cookie settings in Internet Explorer;
• Cookie settings in Firefox;
• Cookie settings in Chrome;
• Cookie settings in Safari web and iOS.

Google allows its users to opt out of Google’s personalized ads and to prevent their data from being used by Google Analytics.

We provide paid products and/or services within the Service. For this purpose, we use third-party services for payment processing (for example, payment processors). As a result of this processing, you will be able to make a payment and we will be notified that the payment has been made.

We will not store or collect your payment card details ourselves. This information will be provided directly to our third-party payment processors.

To enable the purchase and to process your payments we use Stripe, the payment processing provider. To understand how Stripe deals with your data please read their Privacy Policy.

We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms of Service).

We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.

In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 3. This section applies only to EEA-based users.

We process your personal data under the following legal bases: 

Under this legal basis, we will send you marketing communications and use cookies. You have the right to withdraw your consent any time by using the unsubscribe link in the footer of our emails. We will also send you push notifications if you allow us to. You can disable notifications any time in the settings of your device.

Under this legal basis, we:

• Provide our Service (in accordance with our Terms of Service);
• Customize your experience;
• Provide you with customer support;
• Communicate with you regarding your use of our Service;
• Process your payments.

We rely on legitimate interests:

• to communicate with you regarding your use of our Service

This includes, for example, sending you an email or push notification to notify you that we have released a new product or reminding to finish a purchase. The legitimate interest we rely on for this purpose is our interest to encourage you to use our Service more often.

• to research and analyze your use of the Service

Our legitimate interest for this purpose is our interest in improving our Service so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of the Service easier and more enjoyable, or to introduce and test new features).

• to send you marketing communications

The legitimate interest we rely on for this processing is our interest to promote our Service, including new products and special offers, in a measured and appropriate way.

• to personalize our ads

The legitimate interest we rely on for this processing is our interest to promote our Service in a reasonably targeted way.

• to enforce our Terms of Service and to prevent and combat fraud

Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorized use of the Service, and non-compliance with our Terms of Service.

We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes and with parties indicated in section 3 of this Privacy Policy. The types of third parties we share information with include, in particular: 

We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers:

• cloud storage providers (Amazon, Google, OVH);
• data analytics providers (Facebook, Google);
• communication service providers (Intercom);
• marketing partners (in particular, social media networks, marketing agencies; Facebook, Google, Twitter, AdRoll);
• payment service providers (Stripe).

We may use and disclose personal data to enforce our Terms of Service, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g., parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

To be in control of your personal data, you have the following rights:

Accessing/reviewing/updating/correcting your personal data. You may review, edit, or change the personal data that you had previously provided on the Website by sending us an email at [email protected].

You may also request a copy of your personal data collected during your use of the Website at [email protected].

Deleting your personal data. You can request the erasure of your personal data as permitted by law by sending us an email at [email protected].

When you request the deletion of your personal data, we will use reasonable efforts to honor your request. In some cases, we may be legally required to keep some of the data for a certain time; in such an event, we will fulfill your request after we have complied with our obligations.

Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof by sending a request to [email protected].

Additional information for EEA-based users:

If you are based in the EEA, you have the following rights in addition to the above:

The right to lodge a complaint with a supervisory authority. We would love you to contact us directly at [email protected], so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work, or where the alleged infringement has taken place.

The right to data portability. If you wish to receive your personal data in a machine-readable format, you can send a respective request to us at [email protected].

We do not knowingly process personal data from persons under 18 years of age. If you learn that anyone younger than 18 has provided us with personal data, please contact us at [email protected].

We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms of Service and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards.

In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here), or (ii) the European Commission adequacy decisions about certain countries (details available here).

Adapty Tech Inc. (“Adapty”) employs various legal instruments for the legitimate transfer of personal data from the European Union, the United Kingdom, and Switzerland to jurisdictions beyond these territories. Adapty complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce. Adapty has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. DPF Principles with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Adapty has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. DPF Principles with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.

If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Under each Data Privacy Framework, the U.S. Federal Trade Commission has the power to enforce rules on Adapty. In certain situations, Adapty might have to share personal data if asked by government authorities, especially for reasons related to national security or law enforcement.

Adapty is responsible for the processing of personal data it receives or subsequently transfers to a third party acting as an agent on its behalf unless Adapty proves that it is not responsible for the event giving rise to the damage. Adapty complies with onward transfer liability provisions in the Data Privacy Framework Principles.

Individuals may exercise their right to request access, review, correction, updating, or deletion of their personal data under our stewardship via email [email protected].

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Adapty commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact Adapty at: [email protected].

If we do not resolve your complaint, Adapty cooperates with panels established by the European Union data protection authorities (“DPAs”), the United Kingdom Information Commissioner’s Office (“ICO”), and the Swiss Federal Data Protection and Information Commissioner (“FDPIC”), who will hear such complaints. You may also have a right to invoke binding arbitration for unresolved complaints.

We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified by available means such as email and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.

California’s Shine the Light law gives California residents the right to ask companies once a year what personal information they share with third parties for those third parties’ direct marketing purposes. Learn more about what is considered to be personal information under the statute.

To obtain this information from us, please send an email message to [email protected] which includes “Request for California Privacy Information” in the subject line and your state of residence and email address in the body of your message. If you are a California resident, we will provide the requested information to you at your email address in response.

We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Service to you). We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Except as otherwise stipulated in this Privacy Policy, this Service does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

You may contact us at any time for details regarding this Privacy Policy and its previous versions. For any questions concerning your account or your personal data please contact us at [email protected].