Adapty privacy policy

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

Table of contents

1. Personal data controller

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.

2. Categories of personal data we collect

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).

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2.1. Data you give us

If you decide to register a personal account on the website, we will ask you to provide an email address, that will be used for signing in to your personal account and informing you about our services, as well as your name, and company/app name. If you decide to register online to participate in the events or get a consultation (for example, to schedule a demo call with our team or sign up for the webinar organized by our team), we will additionally ask for your country, phone number, and position. We will also ask you to provide your payment details to enable you to create payment orders via your personal account.

2.2. Data we collect automatically:

We collect data about your referring app or URL (that is, the app or place on the Web where you were when you tapped/clicked on our ad).

2.2.2. Device and Location data.
We collect data from your device. Examples of such data include: language settings, IP address, time zone, type and model of a device, device settings, device memory, operating system. 

2.2.3. Advertising IDs.
We collect your Universally Unique Identifier (“UUID”), Apple Identifier for Advertising (“IDFA”), Identifier for Vendor (“IDFV”) or Google Advertising ID (“AAID”) (depending on the operating system of your device) when you access the Website from a mobile device. You can typically reset these numbers through the settings of your device’s operating system (but we do not control this). 

2.2.4. Transaction data.
When you make payments through the Service, you need to provide financial account data, such as your credit card number, to our third-party service providers. We do not collect or store full credit card number data, though we may receive credit card-related data, data about the transaction, including: date, time and amount of the transaction, the type of payment method used.

2.2.5. Cookies
A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our Service. A persistent cookie remains on your hard drive for an extended period of time. We also use tracking pixels that set cookies to assist with delivering online advertising. Cookies are used, in particular, to automatically recognize you the next time you visit our website. As a result, the information, which you have earlier entered in certain fields on the website may automatically appear the next time when you use our Service. Cookie data will be stored on your device and most of the times only for a limited time period.

3. For what purposes we process your personal data

We process your personal data:

3.1. To provide our Service

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

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To host personal data and enable our Service to operate and be distributed we use Amazon Web Services, which is a hosting and backend service provided by Amazon. Read more about Amazon’s approach to privacy in its Privacy Policy. To host personal data and enable our Service to operate and be distributed, we use OVHcloud, which is a hosting and backend service provided by OVH US LLC. Read more about OVH’s approach to privacy in its Privacy Policy.

3.2. To provide you with customer support

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.

3.3. To communicate with you regarding your use of our Service

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.

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The services that we use for these purposes may collect data concerning the date and time when the message was viewed by our Service’s users, as well as when they interacted with it, such as by tapping/clicking on links included in the message. Intercom provides us with message and customer service tools, which enable us to communicate with you within the Service. Intercom uses your data to provide and fulfill its services (as set forth in their terms of service). Read more about Intercom’s approach to privacy in its Privacy Policy.

3.4. To research and analyze your use of the Service

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.

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We use Facebook Analytics, which is a service provided by Facebook that allows us to use different analytical tools. On Facebook Analytics we get, in particular, aggregated demographics and insights on how many people visit our Service, how often users make purchases, and other interactions. Learn more about Facebook’s approach to data from its Privacy Policy. To analyze how visitors use our Website and to measure effectiveness of some ads we use Google Analytics, a web analysis program of Google. In order to provide us with analytics, Google Analytics places cookies on your device. On Google Analytics we get, in particular, aggregated information on the data you enter on our Website and users’ interactions within the Website. Along with Google Analytics we use Google Tag Manager. You can read more about how Google Tag Manager deals with data privacy and security here. Google allows you to influence the collection and processing of information generated by the Google, in particular, by installing a browser plug-in, available here. You can read more about how Google uses information here. On our Service, we also use Yandex Metrica, a web analytics service provided by Yandex. Yandex Metrica uses cookies to help us analyze how visitors use the Website. Yandex will use your data for the purpose of evaluating your use of the Website, compiling reports on Website activity for website operators and providing other services relating to the Website activity. In order to deactivate the data collection on the part of Yandex Metrica, you can use the browser add-on developed by Yandex. Learn more about how Yandex uses data in its Privacy Policy.

3.5. To send you marketing communications

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.

3.6. To personalize our ads

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:

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.

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

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We value your right to influence the ads that you see, thus we are letting you know what service providers we use for this purpose and how some of them allow you to control your ad preferences. We use Facebook pixel on the Service. Facebook pixel is a code placed on the Service collecting data that helps us track conversions from Facebook ads, build targeted audience and remarket to people who have taken some action on the Service (for example, made a purchase). We use Facebook Advance Matching to you optimize our Facebook ads to drive better results. We use Facebook Ads Manager together with Facebook Custom Audience, which allows us to choose audiences that will see our ads on Facebook or other Facebook’s products (for example, Instagram). Through Facebook Custom Audience we may create a list of users with certain sets of data, such as an IDFA, choose users that have completed certain actions in the Service (for example, visited certain sections of the Service). As a result, we may ask Facebook to show some ads to a particular list of users. Because of that more of our ads may show up while you are using Facebook or other Facebook’s products (for example, Instagram). You may learn how to opt out of advertising provided to you through Facebook Custom Audience here. Facebook also allows its users to influence the types of ads they see on Facebook. To find how to control the ads you see on Facebook, please go here or adjust your ads settings on FacebookGoogle Ads is an ad delivery service provided by Google that can deliver ads to users. In particular, Google allows us to tailor the ads in a way that they will appear, for example, only to users that have conducted certain actions with our Service (for example, show our ads to users who have made a purchase). Some other examples of events that may be used for tailoring ads include, in particular, visiting our Website. Google allows its users to opt out of Google’s personalized ads and to prevent their data from being used by Google Analytics. We use Twitter Ads provided by Twitter to deliver advertising. Twitter Ads allows us to choose specific audiences based on geographic areas or user’s interests. As a result, we may ask Twitter to deliver our ads to a certain list of users. Twitter allows you to opt-out its internet-based advertising. Please also see the Privacy Policy of Twitter. We use AdRoll Ads to deliver advertising. AdRoll Ads allows us to choose specific audiences based on geographic areas or user’s interests.  Please also see the Privacy Policy of AdRoll.

3.7. To process your payments

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.

3.8. To enforce our Terms and Conditions of Use and to prevent and combat fraud

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).

3.9. To comply with legal obligations

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.

4. Under what legal bases we process your personal data

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: 

4.1. Your consent;

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.

4.2. To perform our contract with you;

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.

4.3. For our (or others’) legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data;

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.

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.

4.4. To comply with legal obligations.

5. With whom we share your personal data

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: 

5.1. Service provider

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).

5.2. Law enforcement agencies and other public authorities

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.

5.3. Third parties as part of a merger or acquisition

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.

6. How you can exercise your privacy rights

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].

7. Age limitation

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].

8. International data transfers

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).

9. Data Privacy Frameworks

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

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.

10. Changes to this privacy policy

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.

11. California’s privacy rights

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.

12. Data retention

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.

13. How "do not track" requests are handled

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.

14. Contact us

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].

Effective as of April 17, 2024.
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