AppLovin Array Privacy Policy

Effective date: June 25, 2024
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AppLovin Corporation (collectively, “AppLovin”, “we,” “us,”, or “our”) provides a suite of products, functionalities, software solutions, and services that consists of the preinstalled Array application(s) (the “App”), the Array Software Development Kit(s) (SDKs), and various other integrations, interfaces, features, content, and advertising products (collectively, the “Array Services”) that help you (“user,” “end user,” or “device user”) discover, engage with, and/or directly download mobile apps and other products or services.

This Privacy Policy describes how we handle personal information that we collect through AppLovin Array Services. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Service. Additionally, and depending on your jurisdiction, this Privacy Policy 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 Privacy Policy. 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 information, including make, model, operating system, and installed apps;
• 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 your interaction with and use of applications and device features, such as which applications have been viewed, clicked on, downloaded, installed and uninstalled, network traffic data, and service options the user chooses

We will create and assign to your device an identifier (Device_Id) that is similar to an account number.

Information We Collect When You Access Our Website

If you choose to access our website, we may collect personal information which is shared with us (such as name, email address, and any other information you provide us when you contact us for support or provide feedback). Our website may also use cookies, web beacons, or other similar technology to collect browsing 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.

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 may also receive information from our partners (who are the manufacturer of your device or your mobile carrier) such as the IMEI and phone number which we use for debugging purposes. 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.

Mobile Application Software Development Kits.  We may use our SDKs in the App, a partner’s 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, automatic updates of our Services, debugging, or engaging in other transactions with us
• Enable you to create an account and otherwise interact with us and our partner apps
• Determine your eligibility for certain products and/or services
• Communicate with you about our Services, including to respond to your customer service requests or respond to inquiries or correspondence you send to us
• Present you with marketing relating to our Services
• Analyze and improve our website, App, products, and services, including analyzing trends and usage
• Analyze market trends and consumer behaviors for internal business purposes
• Prevent fraud, detect, investigate, or remediate security or other legal concerns
• Comply with applicable laws and regulations or respond to legal process or law enforcement requests
• 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 (Direct Download Services described in the next section), unless specified otherwise elsewhere, we may disclose or share your information in the following ways:

• With the recommended apps, our affiliates, and our business partners. When you use Array Services, 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 Privacy Policy and the agreements we enter into with them.
• 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 Policy; 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.

Direct Download Services

How We Use Your Direct Download Personal Information

When you choose to install certain applications on a device that includes Array functionalities, we use the information we collect to enable the direct download of such applications. We refer to such information as “Direct Download Personal Information,” and such functionality as “Direct Download Services.” 

More specifically, we may use your Direct Download Personal Information to:

• Provide our Direct Download Services to you, including automatic updates of our Services and debugging
• (For U.S. users only) Perform analysis to improve our products, services and technologies
• Communicate with you about our Services, including to respond to your customer service requests or respond to inquiries or correspondence you send to us
• Prevent fraud, detect, investigate, or remediate security or other legal concerns
• Comply with applicable laws and regulations or respond to legal process or law enforcement requests
• Fulfill any other purpose for which you provide it or consent

Direct Download Services do not make any app recommendations, and we do not use your Direct Download Personal Information to make any app recommendations. 

How We Share Your Direct Download Personal Information

In operating our business and working to provide you Direct Download Services, unless specified otherwise elsewhere, we may disclose or share your Direct Download Personal Information in the following ways:

• With our service providers. We transfer your Direct Download Personal Information to service providers, and other partners who support our business, such as providing technical infrastructure services, analyzing how our Direct Download Services are used, or providing customer service. These partners must adhere to strict confidentiality obligations in a way that is consistent with this Privacy Policy and the agreements we enter into with them.
• With third parties for legal or security reasons. We may share your Direct Download Personal Information if we reasonably believe that disclosing such Data 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 Policy; 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 Direct Download Personal Information in connection with such transaction or proceeding before and or after the transaction closes or the proceedings are completed. We may also disclose your Direct Download Personal Information in the event of insolvency, bankruptcy, or receivership.
• With your consent. We may share your Direct Download Personal Information in other ways if you give us consent or direct us to do so.

We do not share your Direct Download Personal Information with any third party advertising partners.

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.

Updated versions of Android enable you to limit collection of information by apps from mobile devices, including Advertising ID and location data, please visit your device’s settings to set these features on your device. You can also make choices about data collection and opt-out of interest-based advertising by certain participating companies by visiting an industry consumer choice platform such as the Network Advertising Initiative (here) or Digital Advertising Alliance (here).

Please note, you may still receive ads on your device 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. 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 business partners; where these interests are not overridden by your data protection rights.

If the processing of personal data is necessary and there is no other lawful basis for such processing, we will generally ensure that consent has been obtained from you. 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]

U.S. Multi-State Privacy Provisions

This section applies only to individual residents (the “Covered Individual Residents”) of the U.S. states that have enacted comprehensive consumer privacy laws, including the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act (“CCPA”), the Colorado Privacy Act, the Connecticut Data Privacy Act, the Virginia Consumer Data Protection Act, the Utah Consumer Privacy Act, and each of their associated regulations, as well as similar consumer privacy laws that may be enacted in the future (collectively, the “Applicable Laws”).

Collection, Use, and Disclosure of Personal Information

The chart below summarizes the categories of personal information we collect, the sources of the personal information collected, the business purposes for our collection, and the categories of third parties with whom we “disclose” or “share” personal information. The chart describes our practices, both current and during the last 12 months.  

Category of Personal Information Collected	Source(s) of Personal Information	Business Purpose(s) for Collection	Third Parties — Disclosure for a Business Purpose
Identifiers, such as IP address and online identifier (like advertising ID)	• You or your device(s) • Affiliates	• Service Delivery • Delivery of Advertisements (not applicable to Direct Download Services) • Technical Support • Customer Support • Analytics  • Business Research & Development (not applicable to Direct Download Services) • Marketing & Promotions (not applicable to Direct Download Services) • Platform Protection & Fraud Prevention • Compliance with Legal Obligations	• Service Providers • Affiliates • Your Specified Recipient(s) • Government Entities/Law Enforcement
Identifiers, such as IMEI and phone number	• Manufacturer of your device or your mobile carrier	• Service Delivery • Debugging • Technical Support • Customer Support • Analytics • Platform Protection & Fraud Prevention • Compliance with Legal Obligations	• Affiliates • Your Specified Recipient(s) • Government Entities/Law Enforcement
Sensitive Personal Information, such as social security numbers, precise geolocation, or genetic and biometric data*	• AppLovin does not collect or seek to elicit end users’ “sensitive personal information” as defined by the Applicable Laws	N/A	N/A
Commercial Information, such as records of services considered or other purchasing or consuming histories or tendencies (e.g., impression, click, install data)	• You or your device(s) • Affiliates	• Service Delivery • Delivery of Advertisements (not applicable to Direct Download Services) • Analytics • Business Research & Development • Platform Protection & Fraud Prevention • Compliance with Legal Obligations	• Service Providers • Affiliates • Your Specified Recipient(s)
Internet or Network Information, such as information regarding interactions with a website, application, or advertisement, or online browser history	• You or your device(s)	• Service Delivery • Delivery of Advertisements (not applicable to Direct Download Services) • Analytics • Business Research & Development • Platform Protection & Fraud Prevention • Compliance with Legal Obligations	• Service Providers • Affiliates • Your Specified Recipient(s)
Geolocation Data, such as county-level geolocation information	N/A	N/A	N/A
Inferences, such as the derivation of information, data, or assumptions from the categories of personal information included above	• You or your device(s) • Affiliates	• Service Delivery • Delivery of Advertisements (not applicable to Direct Download Services) • Analytics • Business Research & Development • Platform Protection & Fraud Prevention • Compliance with Legal Obligations	• Service Providers • Affiliates

*AppLovin does not collect or seek to elicit end users’ “sensitive personal information” as defined by the Applicable Laws. This means that AppLovin does not collect social security numbers, drivers’ licenses, financial account or credit card numbers (except as provided by our business customers to us for payment processing purposes), precise geolocation, racial and ethnic characteristics, religious and philosophical beliefs, union membership, the contents of messages (mail, email, or text), mental or physical health condition or diagnosis, sex life or sexual orientation, genetic and biometric data, or personal data from a known child.

Selling or Sharing of Personal Information

AppLovin does not “sell” information as most people would commonly understand that term; AppLovin does not, and will not, disclose your personal information in direct exchange for money or some other form of payment. In addition, AppLovin does not “share” personal information about you with any third parties for “cross-context behavioral advertising.”  AppLovin only “shares” your personal information with its affiliates, service providers, your specified recipients, or government entities/law enforcement if so required. The chart included above sets forth the categories of third parties with whom we have “shared” personal information within the last 12 months.  

Your Privacy Rights

As a Covered Individual Resident, you may be able to exercise the following rights in relation to the personal information that we may have collected about you, subject to certain limitations and requirements, including the verification of your identity and our right to retain information to comply with our legal obligations, among other circumstances.

Privacy Right	Brief Details
Know and Access your Personal Information	You may request, up to two times in a 12-month period, that we disclose to you the categories and specific pieces of personal information that we have collected about you, the categories of sources from which your personal information has been collected, the business or commercial purpose for collecting your personal information, the categories of personal information that we disclosed for a business purpose, any categories of personal information about you that we sold or shared, the categories of third-parties with whom we have shared your personal information, and the business or commercial purpose for selling your personal information, if applicable.
Request Deletion of your Personal Information	You have the right to request that we delete certain personal information that we may have collected from you.
Opt-Out of the “Sale” or “Sharing” of your Personal Information	To the extent AppLovin “shares” personal information about you for purposes of serving you with personalized ads or content, otherwise known as “interest-based advertising,” “targeted advertising,” or “cross-context behavioral advertising,” you have the right to opt-out of any future “sales” or “sharing” of your personal information as defined by the Applicable Laws (and as explained below).
Non-Discrimination	You have the right to exercise the rights conferred on you by the Applicable Laws without discrimination.
Data Portability	You have the right to request that we transmit certain personal information that we may have collected from you to other entities, unless transmitting the information would not be technically feasible.
Correct Inaccurate Information	You have the right to request that we correct errors or inaccurate information in the personal information that we may have collected from you.
Opt-Out of Sharing for Cross-Contextual Behavioral Advertising	To the extent AppLovin “shares” your personal information for “cross-contextual behavioral advertising,” often referred to as “interest-based advertising” or “targeted advertising,” you have the right to opt-out of such “sharing.”
Limit the Use or Disclosure of Sensitive Personal Information	In certain circumstances, you have the right to limit the use of any sensitive categories of personal information. As noted above, AppLovin does not collect or seek to elicit sensitive categories of personal information.
Opt-Out of the Use of Automated Decision Making	In certain circumstances, you have the right to opt-out of the use of automated decision making in relation to your personal information.

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 sharing, or any other right you may have under applicable law, please submit a request by going to “Manage my privacy choices” under your application’s or device’s “Settings” or emailing us at [email protected] or by writing to us at the physical address in the “Contact Us” section below, with the subject line “Data Privacy 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.

Depending on your state, if you have submitted a request that you believe we have not fulfilled, you may contact us to appeal our decision by replying to our response to your request, or by contacting us at [email protected].

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 U.S. MULTI-STATE PRIVACY 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 help protect the security of the information collected through the Services 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.

Data Storage and 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 EU Standard Contractual Clauses (as mentioned above under “Specific Provisions For EU/UK Consumers” – “International Transfers”).

Children’s Privacy

The Services are designed for individuals above the minimum age to consent for data processing (for example, 13 years old in the United States, and 16 years old in some parts of the EU) and not intended for use by children. We do not knowingly collect or otherwise process personal information from children, including those in the European Economic Area, the United Kingdom, and Switzerland, except to comply with law or to support our legitimate interests or the legitimate interests of our partners as described above.  If you believe your child has provided us with personal information, please contact us at [email protected] and we will make reasonable efforts to delete the information from our records.

Changes to the Privacy Policy

We reserve the right to amend this Privacy Policy from time-to-time. Any material change will be reflected in this Privacy Policy. We will indicate the date this Privacy Policy was last updated. By continuing to use the Services after that date, you agree to the privacy practices contained in the updated Privacy Policy.

How to Contact Us 

If you have any questions or comments about this Privacy Policy, 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].