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 marketing ad network platform (the “Platform“) accessed through the website located at 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 users with access to data, information, and other content (“Content“), as well as features, resources, and services (“Services“), relating to AdGem’s Platform.

If you are viewing our Platform to sign up as a developer, advertiser, or publisher (“Customer“), on sign-up or Account creation you will be requested to enter into an agreement with AdGem (“Agreement“). That Agreement may contain additional privacy disclosures and obligations. If there is any conflict between the Agreement and this Privacy Policy, the Agreement prevails.

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 those changes in this Privacy Policy. 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 end of this Privacy Policy.

Please read this Privacy Policy carefully to understand our views and practices regarding your personal information and how we will treat it. By visiting this Platform, you are freely accepting and consenting to the practices in this Privacy Policy. You may withdraw your consent at any time and for any reason with effect to future data processing by contacting use at the address listed below in the Section titled “Communications”. Without your consent, AdGem will use personal information, only insofar as such processing is permitted by applicable law (e.g., for the performance of an Agreement between AdGem and you) or where such processing is necessary for compliance with a legal obligation to which AdGem is subject.

1. Collection of Personal Information . Personal information refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to, directly or indirectly, a particular consumer or household. 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 Service or Content, or otherwise interact with us or other Users of the Platform. 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.

In addition to personal information that we may receive from you, AdGem may collect other information from Users using the following technologies:

  • Cookies . “Cookies” are small bits of information that the Platform places on the hard drive of your computer. 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. 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 webpages 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 webpage. 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.
  • Device Information . We may collect information about the mobile device or computer you use to access the Platform, including without limitation the hardware model, operating system and version, browser type, unique device identifiers, and mobile network information.
  • 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. By downloading and using the Customer’s application, end users give permission to share information collected by the SDK with AdGem under this Privacy Policy.

We refer to all of the above information as “Internet or Network Activity“.

AdGem participates in behavioral-based advertising. This means that a third party may use technology (e.g., a cookie) to collect Internet or Network Activity 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, we may also receive information about you from other sources, including Customers, third parties, or publicly available sources.

Lastly, we may collect personal information that is necessary for our legitimate interests, which will be disclosed to you at the time of collection. AdGem will use this information for the purposes of which it was collected.

2. USE OF PERSONAL INFORMATION . AdGem’s primary purpose in collecting personal information, including Internet or Network Activity, is to provide you with advertisements about products and services that match your interests. AdGem may also use personal information about you for various purposes, including without limitation to:

· To help diagnose problems with the Platform, to administer the Platform, and to enhance the Platform for optimal User experience.

· To monitor the usage and performance of the Platform, and to determine aggregate information about our Users and usage patterns.

· To customize Content and Services that may be of interest to our Users.

· To identify you when you access and use any Sites or Applications.

· To facilitate transactions and process payments.

· To provide you with more relevant advertisements.

· To send Users materials, updates, and product information regarding the Platform.

· To provide maintenance, support, and customer service for the Platform.

  • To conduct research and analysis.

· To contact Users for information verification purposes.

· To fulfil other legitimate purposes permitted by applicable law.

3. Sharing of Personal Information .

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 policy, and we may do so with your consent. AdGem 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). AdGem may share your personal information with service providers that perform services for AdGem, such as providing hosting services, marketing assistance, analyzing User data, processing payment card information, and for other legitimate purposes permitted by applicable law. There may also be instances when AdGem may disclose your personal information without providing you with a choice in order to protect the legal rights of AdGem, other affiliated companies or their employees, agents, and contractors; to honor a request that you have made through the Platform; to protect the safety and security of other Users; to protect against fraud or for risk management purposes; or to comply with the law or legal process. AdGem shares Internet and Network Activity with the customers of our Platform. In addition, if AdGem sells all or part of its business or makes a sale or transfer of assets or is otherwise involved in a merger or business transfer, AdGem may transfer your personal information to a third party as part of that transaction.

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, you “opt in” to allow AdGem to provide such personal information to a social networking site without your further consent. 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.

4. Public Forum and Messaging . AdGem may offer public discussion forums and bulletin boards. Please note that information that you disclose in these public forums become 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.

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. While there is no such thing as “perfect security” on the Internet, we will take reasonable steps to ensure the safety of your personal information.

6. Access & Choice . AdGem has implemented the following procedure that you may use to access, correct, or delete your personal information, or choose how your information is used:

· You may have a right, in accordance with applicable laws, to access, update, correct, and in some cases requests deletion of the personal information that we hold about you. 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.

· If you wish to stop receiving email marketing communications from AdGem, please contact us at the address listed below or clicking the “Unsubscribe” in any marketing communications. If you opt out, we may still send you non-promotional communications, such as those about your Account or to facilitate Content or Services that you have made or accepted.

· Some web browsers and devices permit you to broadcast a preference that you not be “tracked” online. At this time AdGem does not modify your experience based upon whether such a signal is broadcast.

7. OPT-OUT. In line with best practice in our industry, we respect your rights to opt-out of receiving advertising. You can limit the advertisements you receive using the following methods:

  • Device Setting . iOS devices include Apple’s advertising control features which can limit ad tracking using the “Limit Ad Tracking” setting. For example, you can do this by going to “Settings” from the device’s home screen; scroll down to “Privacy”; select “Advertising”; and turn on “Limit Ad Tracking”. In Android devices, you can activate the “Opt out of interest-based ads” setting. For example, you can do this by going to “Settings” on the device; select “Google Settings”; select “Ads”; and check the box labelled “Opt-Out of Interest-Based Ads”. 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”) and Digital Advertising Alliance (“DAA”) opt-out tools to learn more about targeted or interest based advertising and to opt out of certain targeting programs not associated with AdGem.

8. 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.


  • Notice to California Residents – Shine the Light . Under California’s Shine the Light law, 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 their direct marketing purposes. This notice will identify the categories of information shared with 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 below.
  • Notice to California Residents – California Consumer Privacy Act (CCPA) . Under the CCPA, California residents have the right to opt out from the sale of personal information to third parties. In addition, the CCPA provides California residents the right to access and delete personal information. To opt-out of the sale of personal information, please send a request to the address found below. AdGem shares Internet and Network Activity with the customers of our Platform. When contacting us, please indicate your name, address, email address, and that you elect not you do not want us to share Internet and Network Activity with our customers. When exercising your rights or otherwise assisting you, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure we do not disclose personal information to any person who is not entitled to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. You will not be subject to discrimination as a result of exercising the rights described herein. You may designate an authorized agent to make a request on your behalf.
  • Notice to Residents of the European Economic Area . 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, we suggest by using the any unsubscribe link contained in an applicable marketing message, or, emailing us at the “Communications” details below). 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. The provision of personal information by you will be for contractual, marketing, or analytical purposes as referred to in this Privacy Policy. 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.
  • 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, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein or in any terms and conditions related to the use of and access to the Platform.
  • Other Websites . 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.

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


Attn: AdGem Legal Department

Email: [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 January 1, 2020