DATA PRIVACY POLICY
for adjoe Ads Network, adjoe Ads Exchange This Privacy Policy is provided by adjoe GmbH, located at An der Alster 42, 20099 Hamburg, Germany ("adjoe," "we," or "us"). We aim to inform you about the processing of your personal data when you are using apps or games (publisher apps), which implement our mobile advertising optimization technology ("adjoe Technology"). adjoe Technology is integrated into mobile apps to deliver personalized advertising experiences. The app providers ("Publishers") may also provide you with additional information regarding the integration of adjoe Technology within their apps.
For our services we operate the following products:
Personal Data
“Personal data” is information, or parts thereof, by means of which you can be identified either directly (e.g. by your name) or indirectly (e.g. by pseudonymized data such as a unique ID). This means that personal data includes, for example, email addresses, addresses, mobile phone numbers, user names, profile pictures, personal preferences and use behavior regarding the apps used on your end device, user content, financial information and health-related information. However, this could also include one-time identifiers such as the IP address of your end device or the browser you use, and other specific information about your mobile device, such as your device's advertising ID.
This privacy policy describes our practices regarding the handling of personal data that we process from the Publishers’ users. Depending on the constellation, we may act as a controller or as a processor on behalf of the Publisher under data protection law. The relevant information about our relationship with the respective Publisher can be found in the Publisher’s privacy policies.
To access the privacy policy governing the processing of data when visiting our adjoe Website, please click here.
1. Provider of adjoe’s Technology
adjoe’s Technology is provided by
adjoe GmbH
An der Alster 42
20099 Hamburg
Germany
Where we are a controller of your data, this is also the entity acting as controller. Should you have any questions or suggestions regarding data protection, please do not hesitate to contact us. You are welcome to direct your data protection concerns to our data protection officer by sending an e-mail to privacy@adjoe.io. Our full contact details are available here.
Our Data Protection Officer:
Mr Stephan Krämer, LL.-M. (Attorney at law, Germany)
KINAST Rechtsanwaltsgesellschaft mbH Hohenzollernring 54 50672 Cologne
You can contact our data protection officer via his website at http://www.kinast.eu.
2. Personal Data processing in connection with adjoe’s Technology
2.1 Data we receive
First of all, we do not know who you (as a user) are. adjoe neither processes direct identifiers, such as names, home addresses, e-mail addresses or similar information of users. That said, we only process data provided by the Publishers, including user information about the interaction with apps, which is recorded, stored and evaluated using temporary identifiers, which adjoe cannot match to you as a person (so-called pseudonyms). If we are acting as a processor on behalf of the Publisher, the Publishers determine the purposes and means on how we process users’ data. We have established several technical and legal measures to safeguard that the Publisher’s users have given their consent for our processing.
Data we receive from Publishers differ. Provided there is a legal basis for processing, we typically process:
2.2 Purposes of data processing and legal bases
We process the data received from Publishers so that they can market ad space for targeted in-app advertising and targeting campaigns. When serving personalized mobile advertising, this gives advertisers the opportunity to target users who are actually interested in their products, offers and content.
Our processing activities include the following purposes. When we act as a controller, we rely on the following legal bases. If several legal bases are specified, the choice of the relevant legal basis depends on the decision of the respective Publisher. Further information can be found in the privacy policy of the Publisher.
Purpose of processing | Legal basis |
Store and/or access information on a device Device or similar online identifiers together with other information (e.g. screen size, supported technologies sensor data reflecting the state or movement of the device, etc.) can be stored or read on your device to recognise it each time it connects to an app or to a website, for one or several of the purposes presented here. | User’s consent (Art. 6 (1) (a) GDPR |
Use limited data to select advertising Advertising presented to you on the Publisher’s app can be based on limited data, such as the app you are using, your non-precise location, your device type or which content you are (or have been) interacting with (for example, to limit the number of times an ad is presented to you). | User’s consent if chosen by the Publisher (Art. 6 (1) (a) GDPR Our legitimate interest in being able to offer our publishers a meaningful product (Art. 6 (1) (f) GDPR) |
Create profiles for personalised advertising Depending on your privacy choices, information about your activity on the Publisher’s app (such as information you submit, content you look at) can be stored and combined with other information about you (for example, information from your previous activity on the Publisher’s service and other websites and apps) or similar users. This is then used to build or improve a profile about you (that might include possible interests and personal aspects). Your profile can be used (also later) to present advertising that appears more relevant based on your possible interests by this and other entities. | User’s consent (Art. 6 (1) (a) GDPR |
Use profiles to select personalised advertising Depending on your privacy choices, advertising presented to you on the Publisher’s app can be based on your advertising profiles, which can reflect your activity on the Publisher’s app or other websites or apps (like the forms you submit, content you look at, purchases you have made within the app), possible interests and personal aspects. | User’s consent (Art. 6 (1) (a) GDPR |
Save and communicate privacy choices In order to respect your privacy choices and fulfil our legal obligations or those of our partners, we collect and communicate the choices a user made to our demand partners (DSPs) (in particular, whether or not device identifiers such as the ID for Advertising for iOS (IDFA), Google Advertising ID (GAID) may be processed according to the user's selection). | Compliance with a legal obligation to which the controller is subject (Art. 6 (1) (c) GDPR |
Measure advertising performance Information regarding which advertising is presented to you and how you interact with it can be used to determine how well an advert has worked for you or other users and whether the goals of the advertising were reached. For instance, whether you saw an ad, whether you clicked on it, whether it led you to buy a product or visit a website, etc. This is very helpful to understand the relevance of advertising campaigns. | User’s consent if chosen by the Publisher (Art. 6 (1) (a) GDPR Our legitimate interest in being able to offer our publishers a meaningful product (Art. 6 (1) (f) GDPR) |
Develop and improve services Information about your activity on the Publisher app, such as your interaction with ads or content, can be very helpful to improve products and services and to build new products and services based on user interactions, the type of audience, etc. This specific purpose does not include the development or improvement of user profiles and identifiers. | Our legitimate interest in improving our product (Art. 6 (1) (f) GDPR) |
Ensure security, prevent and detect fraud, and fix errors Your data including sensor metrics regarding device state and physical movement to identify automated patterns, can be used to monitor for and prevent unusual and possibly fraudulent activity (for example, regarding advertising, ad clicks by bots), and ensure systems and processes work properly and securely. It can also be used to correct any problems you, the publisher or the advertiser may encounter in the delivery of content and ads and in your interaction with them. | Our legitimate interest in being able to offer our Publishers a useful and error-free product (Art. 6 (1) (f) GDPR) |
We are unable to combine the data we receive in a way that would enable us to personally identify users and we do not combine the data with any third-party data that would enable us to do so.
2.3 Data recipients
adjoe only discloses data to other parties if this is necessary for the implementation of campaigns or other purposes listed in this privacy notice, or if another legal basis for the disclosure of data exists. The collection and processing of usage data by the mobile app Publishers are controlled by the respective Publishers.
In the context of the serving of ads, data are exchanged between adjoe and partner advertisers on the bid request level (to get an ad) or in aggregated form for reporting and fraud analysis. Partner advertisers include demand side platforms, ad-exchanges and advertisers. This might include the following information on the bid request level:
If adjoe uses its own external service providers (e.g. data centers), the service providers may only use the data to fulfill their task. All service providers have been carefully selected and commissioned. They are bound by the instructions of adjoe and are regularly checked. In cases where data is processed in countries outside the European Union, appropriate safeguards are always in place to protect data subjects, such as Adequacy Decisions by the European Commission or Standard Contractual Clauses (SCCs).
2.4 Separate Controllers
adjoe is a service provider, so we work with Publishers to process data.
2.4.1 We provide the Publisher with a technical solution that the Publisher integrates into its apps. This technology enables the data described in this policy to be collected. We are also supporting the Publishers, in the processing of enquiries from data subjects.
2.4.2 The Publisher obtains consent where necessary and implements transparency information towards you. They pass this information on to us to communicate the scope and permissibility of the data processing.
2.4.3 The Publishers and adjoe will ensure that the necessary data security is in place. Both we and the Publishers will also fulfil our reporting and notification obligations individually but will support and inform us to the extent necessary.
2.4.4 You can exercise your rights as a data subject as described below (see section 3 - Users’ rights).
2.5 Retention period.
The collected data are stored for as long as the usage data and data about interactions with ads and installations of new apps are required for the described purposes. After that, the data is deleted or completely anonymized. We will further delete personal data immediately when the Publisher informs us that the user has withdrawn consent. We will, however, retain and use information as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
3. Users’ rights
If adjoe is acting as the controller, users have the following rights regarding their personal data:
Right to Access: You have the right to know how adjoe processes your personal data. This includes receiving information about the data processing activities and a summary of the data stored about you. You can also reach out to the Publisher, and if necessary, we will assist them in providing this information.
Right to Rectification: If any of the data we hold about you is incorrect or outdated, you have the right to request its correction.
Right to Erasure: You can ask for your data to be deleted. If deletion is not possible due to legal requirements, your data will be blocked and retained only for the specific legal purpose.
Right to Restrict Processing: You may request that we limit the processing of your personal data, for example, if you believe the data is inaccurate.
Right to Data Portability: You have the right to receive a digital copy of the personal data you have provided to us. Upon request, adjoe will send this data to you in a machine-readable format.
Right to Object: You have the right to object to the processing of your personal data when it is based on legitimate interests, as outlined in Art. 6(1)(f) GDPR. Specifically, you can opt out of data processing for advertising purposes at any time. You can use the opt-out function provided below to do so.
Right to Withdraw Consent: If you have previously consented to the processing of your personal data, you can withdraw that consent at any time. To do so, please follow the instructions provided by the Publisher.
Right to lodge a complaint: You also have the right to lodge a complaint with the data protection supervisory authority responsible for adjoe, which is the Hamburgische Beauftragte für Datenschutz und Informationsfreiheit (HmbBfDI). You can find their contact details here: https://www.datenschutz-hamburg.de/wir-ueber-uns-kontakt/wie-erreichen-sie-uns.html. Alternatively, you can contact your local data protection authority, who can forward your complaint to the relevant authority.
4. Opt-out
If you no longer wish to receive targeted in-app advertising that is deployed based on adjoe’s Technology, you may opt out at any time using your mobile device's built-in privacy settings.
Android Users (version 2.3 and above)
You can opt out of personalized ads or delete your advertising identifier entirely by navigating to Settings > Privacy > Ads and selecting "Delete advertising ID" (exact steps may vary depending on your device version and manufacturer).
iOS users (version 6 and above)
You can manage tracking permissions on an app-by-app basis or block tracking entirely. Go to Settings > Privacy & Security > Tracking and toggle off "Allow Apps to Request to Track."
Please note that these are device settings and will disable interest-based ads from all providers, and not just for us. We have decided to offer this way of opting-out, as we estimate users will either want to receive interest-based advertising or no interest-based advertising at all. The above-described way is most efficient to achieve that goal.
You may also request deleting your data or opt-out of targeted in-app advertising via e-mail to privacy@adjoe.io.
5. Data processing in Third Countries
Please note that, to the extent necessary, we may transfer your personal data to our partners or to service providers based outside of the European Economic Area (EEA) and process your data on servers outside of the European Economic Area (EEA).
If we process data in a Third Country (i.e., outside the European Union (EU), the European Economic Area (EEA), where the privacy laws may not be as protective as those in your location) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities or companies, this is only done in accordance with the strict legal requirements of the EU and we ensure that your data is treated in accordance with the provisions of this data privacy policy.
Subject to express consent or contractually or legally required transmission, we process or allow the data to be processed only in third countries with a level of data protection recognized by an adequacy decision of the EU Commission, a contractual obligation through so-called standard contractual clauses of the EU Commission, the existence of certifications or binding internal data protection rules in accordance with Articles 44 to 49 of the GDPR; further information on this can be found on the websites of the EU Commission at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en. Where necessary, we and our partners or processors may also take additional measures to ensure the protection of your personal rights, the confidentiality of your personal data and compliance with applicable EU laws and regulations.
6. Transparency and Consent Framework (TCF) Compliance
We participate in and comply with the IAB Europe Transparency and Consent Framework (TCF) and adhere to its Policies and Specifications. Our participation ensures that user consent and privacy preferences are collected, stored, and transmitted in accordance with the TCF’s standardized processes. We operate under the TCF v2.2 framework as a registered vendor (Vendor ID 1373) and process personal data based on the consent signals and legitimate interest indications provided through the TCF. For more information about the TCF and participating vendors, please visit https://iabeurope.eu/tcf/.
7. Changes to this Privacy Policy
We reserve the right to change or update this Privacy Policy at any time in accordance with the currently applicable data protection regulations. The adjoe website always contains the latest version of this adjoe Privacy Policy.
Updated: July 2026