Effective date: April 21, 2023
AppLovin Corporation (collectively, “AppLovin”, “we,” “us,”, or “our”) provides a mix of products and services through various channels. We provide certain products and services primarily to our mobile operator and handset manufacturer partners, through mobile applications and related software solutions embedded in devices distributed by such business partners.
This Privacy Notice (“Notice”) describes how we handle personal information that we collect through our AppLovin Array Services app (“App”), related software solutions, and websites including https://www.applovin.com/ (“Website”) (collectively, the “Services”). Unless otherwise defined in this Notice, terms used in this Notice have the same meanings as in our Terms of Service. Additionally, this Notice describes certain rights and choices concerning your information that may apply to you. By using or accessing the Services in any manner, you acknowledge and agree to the practices and policies outlined in this Notice. If you do not agree with our privacy practices, please stop using our Services.
Index
Personal Information We Collect
We receive the following information in order to provide the Services and to better service users and our business partners:
Information We Collect When You Use Our Services
If you are a user who interacts with our Services, we may collect certain information including the following from our business partners, the user’s mobile device, or directly from the user:
- Device make, model, and operating system;
- Device properties related to screen size, orientation, audio, battery, device memory usage, settings, and boot time;
- Device settings related to accessibility features, font size, theme;
- Carrier;
- Operating system;
- Country, time zone and locale settings (country and preferred language);
- Network connection type and speed;
- IP address;
- Internet browser user-agent used to access the Services;
- Advertising IDs (GAID); and
- App usage information, including but not limited to:
- Time and duration of your App use
- Log information regarding the use of applications and device features, which applications have been downloaded, installed and uninstalled, network traffic data, and service options the user chooses
We will create and assign to your device an identifier that is similar to an account number.
If you choose to access our Website, we may collect personal information which is shared with us (such as name, email address or other address you provide, and any other information you provide us when you contact us for support or provide feedback).
Information from Other Sources
Our advertising partners may share with us information that describes how often users use their applications and information about events that occur within their application. We use this information to provide you the Services and to improve the products and services we deliver to you, including to prevent fraud and/or to verify your identity. We may also combine information we collect with other information we derive through analytical techniques, and we use that combined information to offer the Services. This type of information may include transactional data related to a consumer’s interaction with an application, such as information about the actions taken in an application like purchases or application installations.
How We Use Cookies and Other Tracking Technologies
Website Tracking. Our Website may use cookies, web beacons, or other similar technology to collect information. You may be able to limit the use of cookies through your browser settings, but note that certain parts of the Website may not function properly without cookies. We also partner with Google Analytics to learn more about how you use our Website. For more information about how Google Analytics works you can visit here. To opt-out of Google Analytics, you can visit here and follow the instructions.
Mobile Application Software Development Kits (SDKs). We may use our software development kits (“SDKs”) in the App and/or in the recommended apps for a variety of purposes, including to provide us with analytics regarding the use of our mobile applications, to integrate with social media, add features or functionality to our app, or to facilitate interest-based advertising. SDKs may enable third parties to collect information directly via our mobile applications.
How We Use Your Personal Information
We use the information we collect for the purpose of providing our Services as well as to perform analysis to improve our products, services and technologies and those of our partners. The information also enables advertising and app recommendations that are most likely suited for our business partners and device users. In addition, we use the information to analyze the performance of advertising campaigns of our business partners and to provide them with performance reports. More specifically, we may use your information:
- To provide our Services to you, including making recommendations for apps you may be interested in, informing you about updates to apps on your phone so you can easily install the latest version, or engaging in other transactions with us
- To enable you to create an account and otherwise interact with us and our partner apps
- To determine your eligibility for certain products and/or services
- To communicate with you about our Services, including to respond to your customer service requests or respond to inquiries or correspondence you send to us
- To present you with marketing relating to our Services
- To analyze and improve our Website, App, products, and Services, including analyzing trends and usage
- To analyze market trends and consumer behaviors for internal business purposes
- To prevent fraud, detect, investigate, or remediate security or other legal concerns
- To comply with applicable laws and regulations or respond to legal process or law enforcement requests
- To fulfill any other purpose for which you provide it or consent
How We Share Your Personal Information
In operating our business and working to provide you the Services, we may share your information in the following ways:
- With the recommended apps, our affiliates, and our business partners. When you use the App, we may share information with the recommended apps, our affiliates to the extent their apps are recommended apps, and business partners (the device carriers and OEMs) that offer our Services, including when necessary to provide our Services and for attribution purposes.
- With our service providers. We transfer information to service providers, and other partners who support our business, such as providing technical infrastructure services, analyzing how our Services are used, measuring the effectiveness of ads and services, providing customer service, or facilitating payments. These partners must adhere to strict confidentiality obligations in a way that is consistent with this Notice and the agreements we enter into with them.
- With Advertising Partners. We share information with our third-party advertising partners to provide our users with advertising services. This information may be used by such third-party partners to measure how effective ads are, showing advertisements to Service users for recommended apps, products and services that are more likely to appeal to them (a practice known as interest-based advertising or behavioral advertising), and to undertake web analytics to analyze traffic and other ad activity to improve the advertising experience.
- With third parties for legal or security reasons. We may share information about you if we reasonably believe that disclosing the information is needed to comply with valid legal process, applicable laws, and regulations; investigate, remedy, or enforce potential violations of our Terms of Use or Privacy Notice; and detect and resolve fraud or security concerns.
- With third parties as part of an acquisition or liquidation. If we are involved in a merger, asset sale, financing, corporate divestiture, reorganization, or acquisition of all or some portion of our business to another company or if we undergo liquidation or bankruptcy proceedings, we may share your information in connection with such transaction or proceeding before and or after the transaction closes or the proceedings are completed. We may also disclose personal information in the event of insolvency, bankruptcy, or receivership.
- With your consent. We may share information in other ways if you give us consent or direct us to do so.
How We Use and Share De-identified and/or Aggregated Information
Personal information and other information may be de-identified and/or aggregated in a way to remove the personally identifying components. De-identified and/or aggregated information is not and will not be treated as personal information and may be used by us and shared with third parties to provide insights into developing or improving products or services, marketing, investment research or for any other legally permissible purposes. These third parties may also use and disclose the de-identified and/or aggregated information for their own business purposes, including to understand consumer shopping behaviors, investment research, market trends and other insights and for any other legally permissible purposes.
Your Privacy Rights and Choices
You may have the right to request access to, correct, amend, delete, port to another service provider, restrict, or object to certain uses of your personal information (for example, direct marketing). We will not charge you more or provide you with a different level of service if you exercise any of these rights. However, when changes are made we may maintain a copy of the unrevised information in our records. You can also contact us about questions or requests relating to your personal information by sending an email to [email protected]. To protect your privacy, before we give you access or let you update your information, we may ask you to verify your identity or provide additional information. We may reject a request for a number of reasons, including, for example, that the request risks the privacy of other users, requires technical efforts that are disproportionate to the request, is repetitive, or is unlawful.
To limit collection of information from mobile devices, including location data, please visit your device’s settings to set the “Limit Ad Track,” “Location Based Services,” or other similar feature on your device. You can also make choices about data collection for certain companies by visiting an industry consumer choice platform such as the Network Advertising Initiative (here) or Digital Advertising Alliance (here). You may still receive ads after limiting processing of information for interest-based advertising, but those ads may be less relevant to your interests.
Specific Provisions For EU/UK Consumers
International Transfers
We may transfer certain personal data to the U.S. While AppLovin participates and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework, in light of the judgment of the Court of Justice of the European Union in Case C-311/18 and the similar announcement from the Swiss Federal Data Protection and Information Commissioner, we do not rely on this framework as a legal basis for transfers of personal data under the General Data Protection Regulation. We continue however to adhere to these principles and we rely on EU Standard Contractual Clauses and other safeguards to enable such transfers.
Lawful Basis for Processing
On certain occasions, we process your personal data when it is necessary for the performance of a contract to which you are a party, such as to provide the Services to you. We may also process your personal data to respond to your inquiries concerning our products and services.
On other occasions, we process your personal data where required by law. We may also process your personal data if necessary to protect your interests or the interests of a third party.
Additionally, we process your personal data when necessary to do so for fraud prevention, improving our network and services, and marketing our services to advertisers and publishers; where these interests are not overridden by your data protection rights.
If the processing of personal data is necessary, we will generally ensure that consent has been obtained from you if there is no other lawful basis for such processing. You have the right to withdraw your consent to processing of personal data at any time.
For questions about data processing, please contact our Data Protection Officer. Visit the “Contact” section below for contact information.
Children
The Services are not intended for use by children (aged 16 or such higher age as required by applicable law). We do not knowingly collect personal information from children through the Services or knowingly allow them to use our Services. If we learn that we have unintentionally collected personal information from a child, we will delete that information. If you believe that we might have collected personal information from or about a child, please contact us at [email protected].
Your Rights
If you are an individual in the EU/UK, you are able:
- To request access to the personal data we hold about you;
- To request that we rectify or erase your personal data;
- To request that we restrict or block the processing of your personal data;
- Under certain circumstances, to receive personal data about you that we store and transmit to another without hindrance from us, including requesting that we provide your personal data directly to another, i.e., a right to data portability; and
- Where we previously obtained your consent, to withdraw consent to processing your personal data.
To exercise these rights described above, please email us at [email protected]. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.
Additionally, you have the right to lodge a complaint against us. To do so, contact the supervisory authority in your country of residence.
[END OF EU/UK SPECIFIC PROVISIONS]
Specific Provisions For California Consumers
These additional provisions for California consumers apply only to individuals who reside in California. The California Consumer Privacy Act of 2018 (“CCPA”) and California Privacy Rights Act of 2020 (“CPRA”) provide additional rights to know, access, correct, delete, and opt out, and requires “businesses” collecting or disclosing personal information to provide notice and a means to exercise those rights.
Your California Privacy Rights. California residents have the rights listed below under the CCPA. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
- Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
- The categories of Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purpose for collecting and/or selling Personal Information.
- The categories of third parties to whom we disclose Personal Information.
- The categories of Personal Information that we sold or disclosed for a business purpose.
- The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.
- Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
- Correct. You can request that we correct any information on your account that is not accurate, complete, or updated by providing us with the necessary information to correct it.
- Deletion. You can ask us to delete the Personal Information that we have collected from you.
- Opt-out of sales. You can opt-out of any sale of your Personal Information.
- Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.
Right to Opt Out of Information Sales
We do not “sell” information about our users as most people would commonly understand that term. However, consistent with common practice among companies that operate online, we do “share” information in the sense that we allow certain third-party advertising networks and other third-party businesses to collect and disclose your personal information directly from your browser or device through cookies or tracking technologies when you visit or interact with our websites, use our apps or otherwise engage with us. These third parties use your personal information for purposes of analyzing and optimizing our Service and advertisements on our websites, on other websites or mobile apps, or on other devices you may use, to personalize content or to serve ads that may be more relevant to your interests, and to perform other advertising-related services such as reporting, attribution, analytics and market research.
How to Exercise Your Rights
To exercise your right to know, right to access, right to correct, right to delete, right to opt out of information sales, or any other right you may have under applicable law, please submit a request by emailing [email protected] or by writing to us at the physical address in the “Contacts” section below, with the subject line “California Rights Request” and specifying which right(s) you would like to exercise (for example, your right to delete). We will need to verify your identity before processing your request. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems. In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf where (i) you provide sufficient evidence to show that the requestor is an authorized agent with written permission to act on your behalf and (ii) you successfully verify your own identity with us.
We aim to respond to a consumer request within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.
[END OF CALIFORNIA SPECIFIC PROVISIONS]
Other Sites and Services
Our Services may link to third-party websites and recommended apps. We are not responsible for the privacy practices or the content of third-party websites and mobile apps. If you have any questions about their privacy practices, you should review their policies and contact them directly.
Security of Your Information
We implement reasonable and appropriate technical and organizational measures to protect the security of your personal information against accidental or unlawful access, destruction, loss, change or damage. However, no security system is impenetrable, and we cannot guarantee the security of your personal information.
Data Retention
We retain the data we collect through the Services for up to 2 years. Information is automatically purged from our system if the Services do not receive any updated information for a device in the last 2 years. Note that we will retain information in our systems for as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Transfer of Personal Information Outside Your Country
We store information that we collect from your device with our cloud storage providers in the United States. Accordingly, please note that if you do not live in the United States, we will transfer your information to and store it in, the United States. If you are located in the European Economic Area, the United Kingdom, or Switzerland, we will transfer your information to the United States based on the Standard Contractual Clauses.
Children’s Privacy
The Services are not intended for use by children (aged 16 or such higher age as required by applicable law). We do not knowingly collect personal information from children through the Services or knowingly allow them to use our Services. If we learn that we have unintentionally collected personal information from a child, we will delete that information. If you believe that we might have collected personal information from or about a child, please contact us at [email protected].
Changes to this Notice
We reserve the right to amend this Notice from time-to-time. Any material change will be reflected in this Notice. We will indicate the date this Notice was last updated. By continuing to use the Services after that date, you agree to the privacy practices contained in the updated Notice.
How to Contact Us
If you have any questions or comments about this Notice, please write to us at:
Data Protection Officer
AppLovin Corporation
1100 Page Mill Road
Palo Alto, CA 94304
You can also contact us via email at [email protected].
