Data Privacy Statement
for adjoe wave and adjoe Ad Exchange
This Data Privacy Statement applies for the services provided by adjoe GmbH, 20099 Hamburg (hereinafter also referred to as “adjoe”, “we” or “us”), when you are using apps or games (hereinafter referred to as “publisher apps”), which implement adjoe’s services for the marketing of their advertising spaces.
The publisher apps are funded by advertisements and provided to you by their publishers and/or developers, who have entered into agreements with us in order to have advertisements presented and displayed within the publisher apps by adjoe and their partners. When using the publisher apps personal data from you, as an end user, will be processed by adjoe and their partners, which is collected by the adjoe SDK integrated into the publisher apps. An SDK (Software Development Kit), is a software component that allows us to serve ads in a mobile app, and to collect information directly from such apps.
For our services we operate the following platforms:
Adjoe and their partners process the data to take part in the auction on the adjoe Ad Exchange by selling advertising impressions to direct advertisers and to optimize the advertising experience for customers.
Further, with our own DSP (adjoe DSP), we also participate in the auctions ourselves and provide advertising space to our own advertising clients.
Your use of the publisher apps will be financed by advertising paid for by advertisers. Therefore, in order to use the publisher apps, you must consent to the processing of certain information mentioned below by adjoe and their partners. If you do not consent to the processing of this data, you may not be able to use the publisher apps or may only be able to use them in a limited way, subject to the Publisher's specifications.
However, you may choose whether certain personal data (your device's advertising ID), which is used to optimize and personalize the advertising experience for you, by serving advertisements which are presumably more interesting or useful for you, is subject to processing.
Because the protection of your privacy is important to us, we would like to inform you with the following information about what personal data we collect when you use publisher apps, that have integrated the adjoe wave SDK and how we handle this data.
You can access this Data Privacy Statement at any time under the “data privacy” heading within the service or at Privacy.
For the personal data processed within the above mentioned adjoe services, adjoe GmbH, 20099 Hamburg (you will find exact contact details in the legal notice in the adjoe partner app or at Imprint) is the “controller” in accordance with the applicable data protection law, in particular the EU General Data Protection Regulation (GDPR).
Should you have any questions or comments about data privacy, please feel free to contact us by post (adjoe GmbH, An der Alster 42, 20099 Hamburg) or send us an email to dataprivacy@adjoe.zone.
“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 Data Privacy Statement covers all personal data that is stored and processed by you when using adjoe wave.
When using the publisher app personal data will be processed by adjoe and their partners, which is collected by the adjoe SDK integrated into the publisher app. SDK, or a Software Development Kit, is a software component that allows us to serve ads in a mobile app, and to collect information directly from such apps.
So, in most cases, we will collect the data automatically during your use of the publisher apps (e.g. in order to present advertisements to you, while performing our services for app publishers and/or developers and advertisers and understand how you use our services and the publisher apps).
In some cases, you may, however, also provide us with immediate access to the data (e.g. when contacting us).
We will use your data to perform and process our services for app publishers and/or developers and advertisers. Other use will only take place due to other statutory obligations or authorization, if you have granted us permission, or if the use is for legitimate interests of adjoe GmbH as the controller of the personal data processed within the adjoe platforms.
The legal basis for the processing of your data may be the following:
You have the right at any time to receive free information about the extent and content of the processing of your personal data by us. You also have the right to request from us the rectification, restriction of processing, or erasure of your personal data.
In the event of data privacy violations, you also have the right to lodge a complaint with the competent supervisory authority.
Further information can be found further down in this Data Privacy Statement, in the following section: “Your Rights as a Data Subject”.
Your use of the publisher app may be financed by advertising paid for by advertisers. In order to (fully) use the publisher apps, you may therefore have to consent to the processing of certain information mentioned below by adjoe and their partners.
Your respective consent will be requested either a) directly by us after you have used the publisher app for a short period of time or b) by the provider of the publisher app when you launch it for the first time before you can actually use the publisher app. For this purpose, the request for your consent will be displayed by means of a pop up on your screen, a system message or a screen prompt.
Can we collect and use your data to tailor your ads and experience?
The game or the app you’re just using is provided to you by its publisher and is funded by advertisements. For this reason, you must consent to the processing of certain information mentioned below in order to use this app.
These advertisements are delivered and displayed within the app through the adjoe wave platform, which is operated by adjoe GmbH, An der Alster 42, 20099 Hamburg, Germany (“adjoe”) and their partners.
Adjoe and their third-party advertisement partners will collect data, including demographic information, and use mobile identifiers and further data for ads and gameplay personalization and measurement.
Platform-Wide Personalization and changing your privacy choice
You can choose not to opt-in to a personalized experience across the adjoe wave platform by declining the personalized capturing of your data as described above and thus rejecting personalized ad display. This will apply to both advertising that comes from adjoe directly as well as from their advertising partners and also across all your applications to the extent that advertisements or experiences are served by adjoe. Please note, that in this case you will still see advertisements when using the app, which may, however, be less interesting or useful for you.
You have the following privacy options:
or
This will be the case if you first have to consent to the transfer of your personal data to adjoe and their partners and agree to the processing of your personal data by adjoe and their partners, when using the publisher app for the first time, e.g. by a pop up or a screen prompt, before you can actually use the publisher app.
In this pop up or prompt, the above options regarding the processing of your personal data (AGREE TO ALL / ACCEPT, BUT DECLINE PERSONALIZED ADS / DISAGREE) should be available to you in the same way and your choice will have the same impact on the processing of your personal data as described in this Data Privacy Statement. However, the exact content and wording of the request for your consent is up to the provider of the publisher app and we have no control over this in these cases.
If you want to enable a personalized experience platform-wide or withdraw your consent, you can access these options at any time by clicking here or by tapping the adjoe Data Privacy icon when or after an ad appears.
Please note that changing your settings for displaying personalized advertisements will enable or disable a full personalized experience across all applications that use the adjoe wave platform, subject to any app-level privacy choices you may make following this opt-in.
The withdrawal of your consent and the termination of the use of the publisher apps is possible at any time with future effect. In the event of withdrawal, your data will be erased from our database and the databases of our partners; if an erasure is not possible, it will be blocked instead of erased. Further use of the publisher apps is no longer possible after the full withdrawal of your consent.
During the use of the publisher app, we log and store certain data automatically. The following data is collected by the adjoe wave SDK integrated into the publisher’s game or app. The data will be sent encrypted to our servers and connected to your end device via a specific and randomly generated, anonymous adjoe-ID-number for further processing:
The data specified above will be used for analytical purposes, particularly in order to show you ads for other games or apps we think you would enjoy– or even to determine that no ads will be presented to you.
Further, this information will be used for billing purposes with the advertising providers (with regard to measuring conversions of advertisements and payment of the agreed commissions per conversion).
The processing of this data takes place based on the consent granted by you (see above) and serves to enable the use of the publisher app by you.
Otherwise, the above-mentioned data will be prepared, and we will process it in a general and anonymized manner in order to generally analyze the use of our services. This data includes the models and product names of the end devices employed for the use of the publisher apps, the version of the operating system, the browser types used and their display resolutions, as well as general details about when which content is accessed, the names of the files requested or which data is accessed most frequently, and their dates and times of access. This data is solely for the needs-based design of our services and therefore to constantly improve our services, and detect and rectify any security flaws.
This data does not enable matches to be made to you personally.
The processing of this data will take place to safeguard legitimate interests of adjoe GmbH as the controller of the personal data processed within the adjoe platforms.
Subject to your privacy choice, your personal data will be retained and processed until you revoke your consent.
However, if you choose not agree to the processing of your advertising ID, we will anonymize your transaction record and process this anonymized data for billing and fraud prevention purposes on the basis of our legitimate interests.
If our server logs also automatically log your IP address, this will take place solely for the purpose of guaranteeing the security of our systems, or for fraud prevention, and the IP address will be automatically erased after 30 days at the latest.
Otherwise, we will only store your personal data for as long as we need it for the performance of our services in adjoe wave, for the fulfilment of your wishes, or for our legitimate interests for the purposes of which we have logged your personal data, or for as long as is permitted or required by law:
When we no longer require your personal data, we will erase it from our systems and records, or anonymize it so that it can no longer be identified. We can retain certain personal data in order to comply with our statutory and regulatory obligations, and to enable us to manage our rights (e.g. the assertion of our rights in court), or for statistical purposes.
The processing of this data therefore takes place to safeguard legitimate interests of adjoe GmbH as the controller of the personal data processed within the adjoe platforms.
We work with various partners who receive your data as part of the auctions in order to be able to place bids and to display advertisements to you, as well as to prevent fraudulent behavior, especially click fraud.
Adjoe’s third party partners may as well use your device's advertising ID and/or your personal data to build a profile about you according to your preferences and household demographic information. Demographic information may include things like statistical data on your presumed gender, age and interests. Adjoe’s partners may use this information to personalize your ad experience to serve future ads you may see on the internet as well as inside the adjoe ad platform.
Among them are the following categories of partners who may have access to your data.
To sell inventory to multiple demand partners, adjoe’s Ad Exchange is integrated with multiple third-party DSPs, all capable of bidding and winning ad impressions. To provide the technical capability, adjoe shares data (device information and user information) with these partners, allowing them to assess and purchase the right inventory. Adjoe is responsible for rendering and displaying these ads with its technology to the user.
Our DSP Partners currently are:
Adjoe Wave (mediation platform) is integrated with several Bidding SDK partners. These partners participate in an auction on the adjoe Ad Exchange but are solely responsible for collecting data from the publisher app by having a contractual relationship with the publisher. Adjoe is not responsible for the advertising content distributed and displayed by these SDK partners to the customer.
Our SDK Partners currently are:
MMPs are used by all advertising partners (regardless of which DSPs). They track advertising (impressions and clicks) by being integrated into the ad unit itself and measure each user's potential app install result.
Our Mobile Measurement Partners currently are:
Please visit adjoe’s third party ad partners' privacy policies linked above for information on the personal data that they may have from all sources, including adjoe, and your data protection rights (e. g. how you can access or delete the information they have about you) under applicable law in relation to the processing of your personal data.
The list of adjoe’s partners may be updated from time to time and is always available here in its current version .
The sharing of your personal data with other third parties without your explicit prior permission will only take place in the following cases, in addition to the other cases named in this Data Privacy Statement:
Please note that, to the extent necessary, adjoe may transfer your personal data to their 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) on condition that the partners or service providers provide sufficient guarantees in relation to required level of data protection, e.g. through a (sub-contracting) data processing agreement which is based on the standard contractual clauses approved by the European Commission Decision (EU) 2021/914 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679, or based on other applicable transborder data transfer mechanisms.
Adjoe has implemented appropriate safeguards with their third party partners and service providers. We consistently ensure the strict data protection made legally binding in the European Union and we ensure that your data is handled in accordance with the provisions of this Data Privacy Statement.
We are obliged to protect your privacy and treat your personal data confidentially. Your data will be stored in our databases, which are only accessible to us and employees specifically trained in data protection.
If we use support from third-party service providers who process your data on our behalf in order to provide our web services, we have ensured that they are subject to the strict conditions of this Data Privacy Statement, and that the use of your data beyond the cases described in this Data Privacy Statement will not take place. All contractors, service providers and their employees are subject extensively to our instructions and are also in particular legally obliged to observe, and trained in, the protection of your data.
In order to prevent the loss or misuse of the data stored by us, we take comprehensive technical and organizational safety precautions, which are regularly reviewed and adjusted to meet technological advances. If it is within our sphere of influence, we use in particular modern encryption techniques as well as a variety of other measures to prevent third parties from obtaining unauthorized information.
However, we would like to point out to you that due to the structure of the internet, it is possible that the data protection regulations and the above-named security measures of other persons or institutions not within our area of responsibility cannot be observed. In particular, data passed on in a non-encrypted form can be read by third parties, even if it is sent via email. We have no technical influence on this occurrence. In these cases, it is the responsibility of the user to protect the data it provides against misuse, by encryption or other methods.
As a data subject in the data processing by adjoe wave, you have the following rights listed in this section.
Please note that we may request proof of your identity and extensive information about your query before we can process it.
Within the framework of the applicable statutory provisions, you have the right at any time to obtain free information about the data stored about you personally, its origin and recipients, and the purpose of the data processing. On presentation of the respective prerequisites, you may also have the right to the rectification of incorrect data, the restriction of the processing, and the erasure of data.
Some forms of data processing are only possible on the basis of your explicit consent. You can withdraw consent already given at any time. The legitimacy of the data processing carried out until the withdrawal will remain unaffected by the withdrawal.
Regarding the data that we process automatically on the basis of your consent or in the performance of a contract, you generally have the right to access it yourself or have it provided to a third party in a customary, machine-readable format. If you require the direct transfer of this data to a third party, this will only take place if this is technically possible with reasonable effort.
In the event of data privacy violations caused by us, you have the right to lodge a complaint with the competent supervisory authority. The supervisory authority responsible for adjoe GmbH in data protection law matters is the Hamburgische Beauftragte für Datenschutz und Informationsfreiheit (HmbBfDI), the contact details of which can be found in the following link: https://www.datenschutz-hamburg.de/wir-ueber-uns-kontakt/wie-erreichen-sie-uns.html.
Should you have any questions or comments about the handling or use of your personal data, should you require information about the personal data stored about you, or should you wish to exercise your other rights named above, you can contact us by post at adjoe GmbH, An der Alster 42, 20099 Hamburg or by sending an email to dataprivacy@adjoe.zone.
As legally stipulated, we have appointed a data protection officer for our company:
Mr Rechtsanwalt Stephan Krämer, LL.M.
KINAST Rechtsanwaltsgesellschaft mbH
Hohenzollernring 54
D-50672 Köln
You can contact our data protection officer via its website http://www.kinast.eu or via email at dataprivacy@adjoe.zone.
On our website, there are links to websites of other service providers. When activating these links, you will be forwarded directly to the websites of the other service providers. You will notice this by the change of URL, amongst other things.
We cannot accept any responsibility for the confidential handling of your data on these websites of third-party companies, as we have no influence on the compliance of these companies with the data protection regulations. Please inform yourself about the use of your personal data by these companies directly on these websites.
We always keep this Data Privacy Statement up-to-date. Therefore, we reserve the right to change it from time to time and update it with changes during the collection, processing and use of your data. Therefore, please read through this Data Privacy Statement regularly. You can access the current version of this Data Privacy Statement at any time under the “Datenschutz” (data privacy) heading in the partner app or at Privacy.
This Data Privacy Statement is available at https://legal.adjoe.zone/wave/adjoe-data-privacy-latest.html in its current version at any time.
Status: 09.03.2023 (Version: 1.2)