Last Updated: September 11, 2026
AdGem LLC (“AdGem,” “we,” “us,” or “our”) provides a performance-based mobile advertising and reward monetization platform that connects publishers, advertisers, and individuals who interact with offers through the AdGem Offer Wall.
This Privacy Policy explains how AdGem collects, uses, discloses, and otherwise processes personal information in connection with our websites, platform, Offer Wall, Player Support services, and related products and services (collectively, the “Services”).
This Privacy Policy applies to personal information we process about:
Publishers and advertisers that participate in the AdGem platform are independent businesses and may separately collect and process personal information under their own privacy policies. Players should review the privacy policy of the application or service through which they access the AdGem Offer Wall and the privacy policies of advertisers whose offers they choose to engage with.
In some circumstances, AdGem processes personal information on behalf of a publisher, advertiser, or other business as a service provider or data processor. In other circumstances, AdGem may process limited personal information for purposes that AdGem determines, such as preventing fraud and abuse, maintaining the security and integrity of the Services, providing Player Support, complying with applicable law, and protecting or enforcing legal rights. AdGem’s role depends on the particular processing activity and applicable law.
1. PERSONAL INFORMATION WE COLLECT
The personal information AdGem collects or receives depends on how an individual interacts with the Services.
A. Player Information
When a Player accesses or interacts with the AdGem Offer Wall or an offer, AdGem may receive or process the following categories of information:
Device Identifiers and Technical Information. This may include device type, operating system and version, application information, IP address, and device identifiers, including mobile advertising identifiers such as Apple’s Identifier for Advertisers (“IDFA”) or Google’s advertising identifier (“GAID”), where available and permitted by applicable platform requirements and the Player’s privacy settings.
App Usage and Event Data. AdGem may receive information regarding interactions or events relevant to making offers available, determining offer eligibility, measuring performance, attributing activity, and determining whether the requirements associated with an offer have been completed.
Reward Transaction Metadata. AdGem may process information associated with the completion, validation, attribution, and fulfillment of rewarded actions, including transaction or event identifiers and other information necessary to determine whether the requirements associated with an offer have been satisfied and whether a reward should be credited.
General Geographic Information. AdGem does not collect or store precise geolocation information from Players. AdGem may infer general geographic information from an IP address, such as a country, state, region, or city, where necessary for purposes such as offer eligibility, attribution, fraud prevention, security, or legal and regulatory compliance.
AdGem may receive this information directly through the Services or from publishers, advertisers, attribution or measurement providers, fraud-prevention providers, and other parties involved in delivering, measuring, validating, or fulfilling offers.
B. Player Support Information
Players who contact AdGem Player Support may voluntarily provide information relevant to investigating and resolving their support request, including:
AdGem collects and uses this information only as reasonably necessary to investigate and resolve the Player’s support request, verify offer completion or reward eligibility, identify technical or attribution issues, prevent fraud or abuse, and communicate with the Player regarding the request.
Players should avoid submitting information that is not reasonably necessary for AdGem to investigate their support request.
C. Business and Account Information
If you are a publisher, advertiser, prospective business partner, service provider, or representative of one of these organizations, AdGem may collect information such as:
Where payment processing is performed by a third-party payment provider, AdGem does not directly store full payment-card information processed by that provider.
D. Website and Technical Information
When you visit an AdGem website, AdGem and its service providers may automatically receive limited technical information such as:
AdGem may use cookies and similar technologies where permitted by applicable law to operate its websites, maintain security, remember necessary preferences, understand the operation of the websites, and provide requested functionality.
AdGem does not use Player personal information to create consumer profiles for targeted advertising or cross-context behavioral advertising.
2. HOW WE USE PERSONAL INFORMATION
AdGem processes personal information only for purposes reasonably related to providing, administering, securing, and supporting the Services and operating its business.
Depending on the circumstances, AdGem may use personal information to:
AdGem does not use Player personal information to build consumer profiles, develop audience segments, infer interests for targeted advertising, conduct cross-context behavioral advertising, or generate generalized behavioral “learnings” unrelated to providing and administering the Services.
AdGem also does not retain Player personal information for those purposes.
3. ADGEM DOES NOT SELL PERSONAL INFORMATION
AdGem does not sell personal information.
AdGem does not exchange Player personal information for monetary or other valuable consideration and does not sell personal information as “sale” is defined under applicable U.S. state comprehensive privacy laws.
AdGem also does not share Player personal information for cross-context behavioral advertising or process Player personal information for targeted advertising.
AdGem does not provide Player personal information to third parties for the purpose of allowing those third parties to build unrelated consumer profiles, develop audience segments, or advertise to Players based on activity across unrelated businesses or services.
AdGem does disclose limited personal information where reasonably necessary to provide and administer the Services, as described below. These operational disclosures are made for purposes such as delivering and validating offers, attribution, reward fulfillment, fraud prevention, Player Support, security, and legal compliance – not for the purpose of selling personal information or enabling unrelated targeted advertising.
4. HOW WE DISCLOSE PERSONAL INFORMATION
AdGem may disclose personal information to the following categories of recipients where reasonably necessary for the purposes described in this Privacy Policy.
Publishers
AdGem may provide information to the publisher through whose application or service a Player accessed the Offer Wall. This may include information necessary to determine offer eligibility, attribute activity, validate completion of an offer, facilitate reward fulfillment, investigate support requests, resolve disputes, or prevent fraud and abuse.
Advertisers and Their Service Providers
AdGem may disclose information to, or receive information from, advertisers and their service providers where necessary to make offers available, measure or attribute rewarded actions, validate offer completion, administer campaigns, investigate discrepancies or support requests, and prevent fraud or abuse.
Attribution, Measurement, Fraud-Prevention, and Technology Providers
AdGem may use companies that provide services necessary to operate the platform, including attribution or measurement, fraud prevention, hosting, cloud infrastructure, communications, security, database management, and other technology services.
These providers receive personal information only as reasonably necessary to perform services or functions for AdGem or otherwise facilitate the Services.
Other Service Providers
AdGem may disclose personal information to providers that support AdGem’s business operations, including providers of customer support, accounting, payment processing, communications, security, and other administrative or operational services.
Affiliates
AdGem may disclose personal information to companies under common ownership or control where reasonably necessary to provide or support the Services or administer AdGem’s business.
Professional Advisors
AdGem may disclose information to lawyers, accountants, auditors, insurers, financial institutions, and other professional advisors where reasonably necessary for them to provide professional services to AdGem.
Government Authorities and Other Parties for Legal Reasons
AdGem may disclose personal information where it reasonably believes disclosure is necessary to comply with applicable law, regulation, legal process, or a valid governmental request; investigate, prevent, or address fraud, abuse, illegal activity, or security incidents; enforce AdGem’s agreements or policies; protect the rights, safety, property, or interests of AdGem or others; or establish, exercise, or defend legal claims.
Business Transactions
Personal information may be disclosed as reasonably necessary in connection with an actual or proposed merger, acquisition, financing, restructuring, sale of assets, bankruptcy, or similar business transaction involving all or part of AdGem’s business.
5. ADVERTISING IDENTIFIERS, DEVICE SETTINGS, AND PRIVACY CHOICES
Mobile operating systems and devices may provide privacy settings that control whether an advertising identifier is available or whether certain tracking activities are permitted.
AdGem may receive device advertising identifiers, such as IDFA or GAID, only where those identifiers are available and their use is permitted by applicable platform requirements, applicable law, and the Player’s applicable privacy settings.
AdGem does not require a Player to change the Player’s device privacy settings, waive a privacy right, or provide consent where the Player chooses not to provide it.
However, rewarded offers depend on the ability of AdGem and other parties involved in the transaction to receive sufficient information to determine whether the applicable offer requirements have been completed. If a Player’s privacy choices, device settings, technical limitations, or other circumstances prevent AdGem from receiving information necessary to attribute or verify completion of an offer, AdGem may be unable to validate the applicable rewarded action or determine eligibility for the associated reward.
AdGem will obtain or rely upon consent where consent is required by applicable law or applicable platform requirements.
6. CHILDREN AND TEENS
The AdGem Offer Wall is not intended for children under 13 years of age or under any higher minimum age applicable in their jurisdiction.
A Player must be at least 13 years old, or the minimum age required by applicable law in the Player’s jurisdiction, to use the AdGem Offer Wall. Individual publishers or advertisers may impose additional eligibility requirements, including a higher minimum age, for particular applications or offers.
AdGem does not knowingly collect personal information from children below the applicable minimum age. If AdGem learns that it has collected personal information from a child below the applicable minimum age in circumstances where the processing was not legally permitted, AdGem will take appropriate steps to delete or otherwise address the information.
AdGem does not sell personal information or share personal information for cross-context behavioral advertising, regardless of a Player’s age.
A parent or guardian who believes AdGem has collected personal information from a child in violation of applicable law may contact AdGem using the information provided in Section 14 below.
7. DATA RETENTION
AdGem retains personal information only for as long as reasonably necessary for the specific purpose for which it was collected or processed.
For Player personal information, those purposes may include:
The applicable retention period may vary based on the type of information and the operational, contractual, fraud-prevention, support, security, or legal purpose for which it is required.
When Player personal information is no longer reasonably necessary for an applicable purpose, AdGem deletes or otherwise disposes of it in accordance with its retention practices and applicable law.
AdGem does not retain Player personal information for the purpose of building consumer profiles, developing audience segments, conducting targeted or cross-context behavioral advertising, or generating generalized behavioral learnings.
Business records and information relating to publishers, advertisers, transactions, contracts, billing, or legal obligations may be retained for longer periods where reasonably necessary to administer AdGem’s business, comply with applicable law, resolve disputes, enforce agreements, or maintain appropriate financial and business records.
8. PRIVACY RIGHTS
Depending on where you reside and subject to applicable law, you may have rights regarding personal information AdGem processes about you.
These rights may include the right to:
Because AdGem does not sell personal information, share personal information for cross-context behavioral advertising, or process Player personal information for targeted advertising, AdGem does not sell or share personal information that requires a consumer to opt out of those activities.
To exercise an applicable privacy right, contact AdGem at privacy@adgem.com.
AdGem may request information reasonably necessary to verify your identity and process your request. Authorized agents may submit requests where permitted by applicable law, subject to applicable verification requirements.
AdGem will not unlawfully discriminate against an individual for exercising an applicable privacy right.
Where AdGem processes particular personal information solely on behalf of a publisher, advertiser, or other business as its processor or service provider, AdGem may direct the request to that business or assist the business in responding to the request, as required by applicable law.
9. ADDITIONAL INFORMATION FOR U.S. RESIDENTS
Certain U.S. state privacy laws provide residents with additional rights regarding their personal information.
Depending on how an individual interacts with the Services, AdGem may process categories of personal information that include:
AdGem processes these categories for the purposes described in Section 2 and may disclose them to the categories of recipients described in Section 4.
AdGem does not collect or store precise geolocation information from Players.
AdGem does not sell personal information and does not share personal information for cross-context behavioral advertising or process Player personal information for targeted advertising.
AdGem retains personal information in accordance with the criteria described in Section 7.
Residents of states providing applicable privacy rights may submit requests using the contact information in Section 14.
10. ADDITIONAL INFORMATION FOR EUROPEAN AND UK USERS
This section applies to individuals located in the European Economic Area (“EEA”), United Kingdom, and other jurisdictions where substantially similar data-protection requirements apply.
Where AdGem acts as a controller of personal information covered by this Privacy Policy, AdGem LLC is the controller.
Legal Bases for Processing
AdGem’s legal basis depends on the particular processing activity and circumstances.
Performance of a Contract. Where processing is necessary to perform a contract with you or take steps at your request before entering into a contract.
Legitimate Interests. Where processing is necessary for AdGem’s or another party’s legitimate interests and those interests are not overridden by your rights and interests. These legitimate interests may include providing and operating the Services; measuring and attributing rewarded actions; validating offer completion and reward eligibility; preventing and investigating fraud, abuse, and manipulation; providing and improving the reliability and security of the Services; providing Player Support; administering business relationships; protecting AdGem’s legal rights and enforcing applicable agreements; and maintaining the security and integrity of AdGem’s systems and Services.
Legal Obligations. Where processing is necessary for AdGem to comply with applicable legal or regulatory obligations.
Consent. Where AdGem relies upon your consent, including where consent is required for particular device access, tracking technology, or other processing under applicable law. Where processing is based on consent, you may withdraw that consent at any time. Withdrawal of consent does not affect processing lawfully conducted before the withdrawal.
AdGem determines the applicable lawful basis before undertaking processing for which AdGem acts as a controller.
Your Rights
Subject to applicable law and applicable exceptions, you may have the right to:
Where AdGem relies on legitimate interests to process your personal information, you have the right to object to that processing in circumstances provided by applicable law.
You may exercise applicable rights by contacting Privacy@adgem.com.
You may also have the right to lodge a complaint with the data protection supervisory authority in the country where you live or work or where you believe a violation occurred. Individuals in the United Kingdom may lodge a complaint with the UK Information Commissioner’s Office.
Sources of Personal Information
AdGem may obtain Player personal information from:
International Transfers
AdGem is based in the United States, and personal information may be processed in the United States and other countries in which AdGem or its service providers operate.
Where applicable data-protection law requires safeguards for a transfer of personal information to another country, AdGem uses an applicable lawful transfer mechanism, which may include an adequacy decision, applicable standard contractual clauses, the UK International Data Transfer Addendum, or another legally recognized transfer safeguard.
You may contact privacy@adgem.com for additional information regarding applicable transfer safeguards.
11. SECURITY
AdGem maintains reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, acquisition, loss, misuse, alteration, or disclosure.
AdGem’s safeguards are designed based on the nature of the information processed and the risks associated with the processing.
No method of transmission over the Internet or method of electronic storage is completely secure, however, and AdGem cannot guarantee absolute security.
12. THIRD-PARTY PUBLISHERS, ADVERTISERS, AND SERVICES
The AdGem Offer Wall is generally accessed through an application or service operated by a third-party publisher and allows Players to interact with offers provided by third-party advertisers.
Publishers and advertisers may independently determine what personal information they collect, how they use it, and how long they retain it. AdGem does not control the independent privacy practices of those third parties.
This Privacy Policy describes AdGem’s processing of personal information. It does not replace the privacy policies of publishers, advertisers, or other third parties.
Players should review the privacy policy applicable to the publisher application or service through which they access the Offer Wall and the privacy policy of any advertiser or third-party service with which they choose to interact.
13. CHANGES TO THIS PRIVACY POLICY
AdGem may update this Privacy Policy from time to time to reflect changes to the Services, AdGem’s privacy practices, or applicable law.
When AdGem updates this Privacy Policy, AdGem will revise the “Last Updated” date at the beginning of the policy and provide any additional notice required by applicable law.
A change to this Privacy Policy will not authorize AdGem to use previously collected personal information for a materially different purpose without providing any notice or obtaining any consent required by applicable law.
14. CONTACT ADGEM
Questions or concerns regarding this Privacy Policy, requests to exercise applicable privacy rights, and other privacy-related inquiries may be directed to:
AdGem LLC
Attn: Privacy
privacy@adgem.com
If you are contacting AdGem regarding a Player Support issue rather than a privacy request, please use the Player Support process made available through the AdGem Offer Wall or applicable Publisher application.
