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AdGem Privacy Policy

AdGem LLC, on behalf of itself and its subsidiaries and affiliates (“AdGem,” “us,” “we,” or “our”), is committed to protecting your privacy. AdGem has prepared this Privacy Policy to describe to you, or if you represent an entity or other organization, that entity or organization, (in either case, “you” or “User”) our practices regarding the personal information that AdGem collects, uses, and shares regarding our mobile app reward monetization marketplace (the “Platform”) accessed through our websites located at https://www.adgem.com and docs.adgem.com/publisher-support, and through various other websites operated by AdGem (each a “Website”), or using mobile and online applications provided by and on behalf of AdGem (each, an “Application,” and each Website and Application treated as a part of the “Platform” for purposes of this Privacy Policy). The Platform provides our developer and publisher customers (“Customers”) the ability to access certain software referred to as the AdGem SDK, for serving advertisements, interactive features, or advertising content (“Advertisements”) to their end users through the Customer’s proprietary mobile application (“Publisher Application”) (collectively, the delivery of Advertisements by AdGem through the Publisher Application, and any accompanying functionality or features, the “Services”)

We also collect information from our Customers about their end users, which may be Users of the Platform, such as Customer promotions, surveys, or contests offered to any end user of a Customer. This Privacy Policy does not apply to end user information that AdGem processes on behalf of its Customers as a “service provider” or “data processor.” Please review the respective Customer’s privacy policy for more information about their privacy practices.

AdGem reserves the right, at any time, to modify this Privacy Policy. If we make revisions that change the way we collect, use, or share personal information, we will post an updated Privacy Policy on this page. In some cases, we may notify you about an update by sending you an email, posting a notice about the update on the Platform, or other means as may be required by applicable law. In all cases, your continued use of the Platform following posting or other notification of changes constitutes your acknowledgement of such changes. You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices. We will note the effective date of the latest version of our Privacy Policy at the top of this Privacy Policy.

1. COLLECTION OF PERSONAL INFORMATION.

AdGem collects personal information when Users voluntarily submit it to us. For example, we may collect or receive information from you when you create an Account, edit your Account Information, use or access Services, or otherwise interact with us or other Users of the Platform. The list below describes the categories of personal information that we may collect about you. We may also collect other personal information that is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

  • Contact information, such as your or your organization’s (as applicable) name, email address, phone number, mailing address, publisher app, and social media handle.
  • Account information, such as your log-in details, information that you store in your account, and other details about your use of the Platform.

  • Transaction history and billing data, such as records of Services purchased from us, and payment amounts and payment methods used to complete transactions. All payment processing services connected with your use of the Platform are provided to you by third-party payment processors. AdGem does not access or keep information related to credit cards, banking information, or other sensitive financial information.

  • Marketing information, such as any preferences you set in your account and any marketing or communications preferences.

  • Survey responses, such as the information you provide in response to our surveys or questionnaires.

  • Communications, such as the information associated with your requests or inquiries, including for support, assistance, or order information, and any feedback you provide when you communicate with us.

In addition to personal information that we may receive from you, AdGem, our service providers, and our advertising partners may automatically collect other information about Users over time on our Platform and other sites and online services, such as:

  • Online activity information, such as the website you visited before browsing to the Platform, pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.

  • Device information, such as your computer or mobile device operating system type and version number, wireless carrier, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, and general location information such as city, state, or geographic area.

We may use the following technologies to facilitate some of this automatic data collection:

  • Cookies. “Cookies” are small bits of information that the Platform places on the hard drive of your computer to uniquely identify your browser or to store information or settings in your browser. Cookies remember information about your activities on the Platform to make your visits to the Platform more enjoyable and valuable to you by providing a customized experience and recognizing your preferences when you visit the Platform. Cookies also help you navigate between pages efficiently, enable functionality, help us understand user activity and patterns, and facilitate online advertising. If you've chosen to disable cookies on your browser, some of the functionality of the Platform may be lost. Certain Services provided by AdGem, require that cookies be enabled in your browser and cannot be used when you have disabled cookies in your browser.
  • Web Server Logs. Web server logs are records of activity created by the computer that delivers the web pages you request to your browser. For example, a web server log may record the search term you entered or the link you clicked to bring you to a web page. The web server log also may record information about your browser, such as your IP address and the cookies set on your browser by the server.
  • SDK Information. We may collect information from a Software Development Kit (SDK) that our Customers integrate into their applications that allows them to provide end users with advertising. SDKs may enable third parties to collect information directly via our Applications.

AdGem participates in behavioral-based advertising. This means that a third party may use technology (e.g., a cookie) to collect information about you so that they can provide advertising about products and services tailored to your interest. That advertising may appear either on the Platform, or on other web sites.

In addition to the information that we collect from you directly or automatically, we may also receive information about you from other sources, including other Users and Customers, our service providers, advertising partners, data analytics partners, operating systems and platforms, social media platforms, and other third parties or publicly available sources.

2. USE OF PERSONAL INFORMATION.

AdGem’s primary purpose in collecting personal information is to provide our Platform to enable our Customers to engage in mobile advertising, and to operate our business. AdGem may also use personal information about you for various purposes, including without limitation those set forth below and as otherwise described in this Privacy Policy or at the time of collection.

To Provide the Platform and Services. We use personal information to provide the Platform and operate our business. For example, we use personal information to:

  • help diagnose problems with the Platform, to administer the Platform, and to enhance the Platform for optimal User experience;

  • identify you when you access and use the Platform and personalize and improve your experience;

  • establish, manage, monitor, and maintain your account;

  • facilitate transactions and process payments;

  • send Users materials, updates, and product information regarding the Platform, their account or transaction, and to respond to any requests, feedback, or questions;

  • provide maintenance, support, and customer service for the Platform;

  • contact Users for information verification purposes; and

  • fulfil any other purpose for which you provide personal information.

Research and Development. We use personal information for research and development purposes, including to study and improve the features and functionality of our Platform and our business, understand and analyze the usage trends and preferences of our Users, and develop new products and services. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes.

Direct Marketing. We may send you AdGem-related or other direct marketing communications as permitted by law, including materials, updates, information, special offers, and promotional material from us and our business partners. You may opt-out of our marketing communications as described in the “YOUR CHOICES” section below.

Behavioral-Based Advertising. We work with third-party advertising companies and social media companies to help us advertise our business and to display ads for our products and services. These companies may use cookies and similar technologies to collect information about you (including the online activity information and device information described above) over time across our Platform and other websites, applications, and services or your interaction with our emails, and use that information to serve ads that they think will interest you. In addition, some of these companies may use hashed customer lists that we share with them to deliver ads to you and to similar users on their platforms. You can learn more about your choices for limiting behavioral-based advertising in the “YOUR CHOICES” section below.

To Comply with Laws and Regulations. We will use personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal processes, such as to respond to subpoenas or requests from government authorities.

For Compliance, Fraud Prevention, and Safety. We may use personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) maintain the safety, security, and integrity of the Platform and our products and services, business, databases, and other technology assets; (b) protect our, your, or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) audit our internal processes for compliance with legal and contractual requirements and internal policies; (d) enforce the terms and conditions that govern the Platform; and € prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With Your Consent. We will disclose your personal information in accordance with your prior direction or, in some cases, we may specifically ask you for your consent to collect, use, or share your personal information, such as when required by law.

3. SHARING OF PERSONAL INFORMATION.

Where required by applicable law, AdGem may ask if you would like us to share your personal information with other unaffiliated third parties who are not described elsewhere in this Privacy Policy, and we may do so with your consent. AdGem may also share your personal information with the following entities or persons:

Related Companies. We may share your personal information with companies that are affiliated with us (that is, that control, are controlled by, or are under common control with AdGem).

Service Providers. AdGem may share your personal information with service providers that perform services for AdGem that are necessary for the orderly operation of our business. For example, we work with service providers that perform hosting services, provide marketing assistance, analyze User data, process payment card information, fraud protection, database management, and for other legitimate purposes.

Social Media Platforms. The Platform may offer you the ability to share your personal information through a social networking site (e.g., Facebook, Twitter, LinkedIn), using such site’s integrated tools (e.g., Facebook “Like” button, or Twitter “Tweet” button). The use of such integrated tools enables you to share personal information about yourself with other individuals or the public, depending on the settings that you have established with such social networking site. Additionally, by making personal information available on the Platform, AdGem may provide such personal information to a social networking site. For more information about the purpose and scope of data collection and use in connection with such social networking site or a site’s integrated tools, please visit the privacy policies of the entities that provide these social networking sites.

Advertising Partners. We may also share personal information with third parties who we partner with for advertising campaigns or that collect information about your activity on the Platform for the purposes described in the “Behavioral-Based Advertising” section above.

Professional Advisors. We may share personal information with persons, companies, or professional firms providing AdGem with advice and consulting in accounting, administrative, legal, tax, financial, debt collection, and other matters.

Law Enforcement. Under certain circumstances, we may be required to disclose personal information to law enforcement, government authorities, and other parties if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

Compliance. We may disclose personal information in the good faith belief that such action is necessary to comply with a legal obligation or for the purposes described above in the section titled “For Compliance, Fraud Prevention, and Safety.”

Business Transaction Participants. We may disclose personal information to third parties in connection with any business transaction (or potential transaction) involving a merger, acquisition, sale of shares or assets, financing, consolidation, reorganization, divestiture, or dissolution of all or a portion of our business (including in connection with a bankruptcy or similar proceedings).

4. PUBLIC FORUM AND MESSAGING.

We may provide functionality that enables you to disclose personal information to other Users of the Platform and the public. For example, AdGem may offer public discussion forums and bulletin boards. Please note that information that you disclose in these public forums becomes public. Use caution in disclosing any personal information. The Platform may also allow you to exchange messages with other Users. We may store these messages in order to deliver them and allow you to manage them. You may also be able to submit content to the Platform (such as comments, questions, stories, reviews, blogs, photos, and videos), and we will identify you by displaying information such as your company name, username, social media handle, or a link to your user profile (as applicable) along with the content you submit. We do not control how other Users or third parties use any personal information that you make available to other Users or the public.

5. SECURITY.

AdGem employs reasonable and appropriate security measures to protect personal information from becoming disclosed to individuals who are not described in this Privacy Policy. Although we will take reasonable steps to ensure the safety of your personal information, no method of transmission over the internet, or method of electronic storage, is fully secure and we cannot guarantee the security of your personal information.

6. YOUR CHOICES.

You may make the following choices regarding your personal information:

Changes to Your Personal Information. We rely on you to update and correct the personal information contained in your account. If the Platform does not permit you to update or correct certain personal information, please submit a request to us using the contact information listed at the end of this Privacy Policy. When updating your personal information, we may ask you to verify your identity before we can act on your request. We will comply with your request as soon as reasonably practicable and in accordance with applicable laws. We may need to retain certain information for recordkeeping purposes, as required under applicable legal obligations, or to complete any transactions that you began prior to requesting such change or access.

Email Marketing Communications. If you wish to stop receiving email marketing communications from AdGem, please contact us at the email address listed at the end of this Privacy Policy or click the “Unsubscribe” link at the bottom of any marketing communications. If you opt out, we may still send you non-promotional communications, such as those about your Account or to facilitate Services that you have accepted.

** “Do Not Track” Signals**. Some web browsers may be configured to broadcast a “Do Not Track” signal to the online services you visit. At this time, the Platform does not currently respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Platform and our Websites may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.

Analytics. The Websites may use Google Analytics to help us analyze how the Website is being accessed and used. You can learn more about Google Analytics cookies by clicking here and about how Google protects your data by clicking here. To opt-out of Google Analytics, you can download and install the Google Analytics Opt-out Browser Add-on, available here.

Advertising Choices. You can limit the use of your information for behavioral-based advertising by using the methods set forth below. Many of the opt-out preferences described in this section must be set on each device and/or browser for which you want them to apply. Please note that some of the advertising companies we work with may not participate in the opt-out mechanisms described below, so even after opting-out, you may still receive behavioral-based advertisements from other companies. If you opt-out of behavioral-based advertisements, you will still see advertisements online but they may be less relevant to you.

  • Browser Settings. You can limit the use of your information for behavioral-based advertising by blocking third-party cookies in your browser settings or using browser plug-ins/extensions.

  • Device Settings. You can use your mobile device settings to limit the use of the advertising ID associated with your mobile device. Please note that even if you opt-out, you will still receive advertising but these messages will not feature interest-based ads that may be more relevant to you.

  • Advertising Alliance Programs. You may use the Network Advertising Initiative (“NAI”), Digital Advertising Alliance (“DAA”), or the European Interactive Digital Advertising Alliance opt-out tools to learn more about targeted or interest-based advertising and to opt out of certain targeting programs from companies participating in these industry opt-out programs. You may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting the user’s choices.

  • Company Opt-Out Mechanisms. Some of the companies we work with may offer their own opt-out mechanisms. For example, you can learn more about how Google uses cookies for advertising purposes by clicking here and opt-out of ad personalization by Google by clicking here.

7. RETENTION OF PERSONAL INFORMATION.

AdGem retains your personal information:

  • For so long as your Account is active or as needed to provide you with Services or to fulfill our contractual obligations;

  • As necessary to comply with our legal obligations, resolve disputes, and enforce our agreements; and

  • For so long as is necessary for the purposes for which we collected such personal information.

8. NOTICE TO CALIFORNIA RESIDENTS (SHINE THE LIGHT).

Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with AdGem are entitled to ask us for a notice describing what categories of personal customer information we share with third parties for the third parties’ direct marketing purposes. This notice will identify the categories of information shared and will include a list of the third parties with which it is shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit a written request to us at the addresses listed at the end of this Privacy Policy.

9. NOTICE TO NEVADA RESIDENTS.

Nevada Revised Statutes Chapter 603A allows Nevada residents to opt-out of the “sale” of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. If you are a Nevada resident who wishes to exercise your “sale” opt-out rights, you may submit a request to us using the contact information listed at the end of this Privacy Policy.

10. NOTICE TO EUROPEAN USERS.

The information provided in this section applies only to individuals in the European Economic Area and the United Kingdom (collectively, “Europe”). The controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation is AdGem LLC, 344 Ogden Ave Ste 2E, Chicago Illinois, 60607, US.

Your Rights. In accordance with applicable data protection laws, you may have the right to request: access to, rectification, and erasure of your personal information; restriction of processing of personal information; objecting to certain processing of personal information; and the right to data portability. Where any processing of personal information is solely dependent upon your consent, you have the right to withdraw such consent at any time (for example, by using the unsubscribe link contained in an applicable marketing message, or, emailing us at the “Communications” details below). If we do not have access to such personal information from you, then we will not be able to undertake certain Services for you. We may withhold information where the search for that information would require disproportionate effort or have a disproportionate effect to, for example, the cost of providing the information, the time it would take to retrieve the data, or how difficult it may be to obtain the information requested. To exercise your rights under these provisions, please contact us at the “Communications” details below. When we receive your requests, we may ask you to verify your identity before we can act on your request. Where you believe that we have not processed your personal information in accordance with applicable data protection laws, you may lodge a complaint with the respective supervisory authority or data protection regulator. In the European Economic Area, you can find your data protection regulator here. In the United Kingdom, you can find your data protection regulator here.

Legal Bases for Processing. The legal bases of our processing of your personal information as described in this Privacy Policy will depend on the type of personal information and the specific context in which we process it. However, the legal bases we typically rely on are set out in the table below. We rely on our legitimate interests as our legal basis only where those interests are not overridden by the impact on you (unless we have your consent or our processing is otherwise required or permitted by law). If you have questions about the legal basis of how we process your personal information, contact us at the “Communications” details below.

Processing Purpose (as described above in the “Use of Personal Information” section) Legal Basis
To Provide the Platform and Services Processing is necessary to perform the contract governing our operation of the Platform or Services, or to take steps that you request prior to engaging our services. Where we cannot process your personal information as required to operate the Platform or Services on the grounds of contractual necessity, we process your personal information for this purpose based on our legitimate interests as further described in this Privacy Policy.
Research and Development Processing is based on our legitimate interests in performing research and development as described in this Privacy Policy.
Direct Marketing Processing is based on your consent where that consent is required by applicable law. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consented or via the relevant Services.
Behavioral-Based Advertising Where such consent is not required by applicable law, we process your personal information for this purpose based on our legitimate interests in promoting our business and providing you with tailored, relevant content.
To Comply with Laws and Regulations Processing is necessary to comply with our legal obligations.
For Compliance, Fraud Prevention, and Safety Processing is necessary to comply with our legal obligations or based on our legitimate interests in protecting our or others’ rights, privacy, safety, or property.
With Your Consent Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or via the relevant Services.

We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Cross-Border Data Transfer. If we transfer your personal information to a country outside of Europe such that we are required to apply additional safeguards to your personal information under European data protection laws, we will do so. Please contact us as at the “Communications” details below for further information about any such transfers or the specific safeguards applied.

11. INTERNATIONAL OPERATIONS.

AdGem is based, and this Platform is hosted, in the United States of America. If you are from a country outside of the United States of America with laws governing data collection, use, and disclosure that may differ from U.S. law and you provide personal information to AdGem, please note that any personal information that you provide to AdGem may be transferred to the United States of America. By providing your personal information, where applicable law permits, you specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein.

Users located in Europe can view more information about cross-border transfers in the section titled “Notice to European Users.”

Other Websites, Apps, and Online Services. This Privacy Policy does not apply to sites or applications offered by other companies or individuals, including third party products and services, that may be displayed as content in a search on the Platform. AdGem encourages you to read the privacy policy of any third-party site or applications before transmitting personal information.

12. COMMUNICATIONS.

If you have any additional questions or concerns about our Privacy Policy or any other privacy or security issue, please contact us at:


AdGem LLC

Attn: AdGem Legal Department

[email protected]

If AdGem needs, or is required, to contact you concerning any event that involves information about you, we may do so by email, telephone, or mail.

Effective as of April 7, 2023