AdAction Interactive LLC, on behalf of itself and its subsidiaries and affiliates (“AdAction,” “we,” “us,” or “our”), respects your privacy. This Privacy Policy explains how we collect, use, disclose, and otherwise process personal information in connection with our websites, customer and partner portals, online services, and our performance advertising and marketing platform (collectively, the “Services”).

This Privacy Policy applies when AdAction determines the purposes and means of processing personal information, including personal information we process for our own business, operational, security, measurement, attribution, fraud-prevention, compliance, and legal purposes. When AdAction processes personal information solely on behalf of an advertiser, publisher, developer, or other customer as a service provider, processor, or subprocessor, that customer is responsible for its privacy practices and instructions, and this Privacy Policy does not govern that processing. Please review the applicable customer’s privacy policy for information about its practices.

We may update this Privacy Policy from time to time. If we make material changes, we will post the updated Privacy Policy and provide any additional notice required by applicable law. The “Effective Date” below identifies the date of the current version.

1. Personal Information We Collect

Depending on how you interact with AdAction and the Services, we may collect the following categories of personal information:

• Contact and business information. Name, business email address, telephone number, mailing address, company, job title, and similar business contact information.
• Account information. Username, authentication information, account settings, advertising materials, campaign information, and other information associated with your use of the Services.
• Transaction and billing information. Information about services purchased, invoices, payments, and transaction history. Payment processing may be performed by third-party payment providers. AdAction does not intentionally store full payment-card or bank-account credentials unless necessary for a specific business purpose and permitted by law.
• Device and technical information. IP address, browser type, operating system, device type, device or advertising identifiers, and similar technical information.
• Advertising, attribution, and event information. Click IDs, impression data, campaign identifiers, transaction or conversion identifiers, attribution information, app or device information, event data, in-app event or purchase information, and hashed identifiers where applicable.
• Usage information. Pages or screens viewed, referring pages, access times, navigation activity, interactions with the Services, and similar usage information.
• Communications. Information you provide when you contact us, request support, respond to a survey, or otherwise communicate with us.
• Marketing preferences. Your preferences regarding communications from AdAction.

We may receive personal information directly from you, automatically when you use the Services, from our customers and business partners, from service providers, and from other sources where permitted by law.

Cookies and Similar Technologies

We and service providers acting on our behalf may use cookies, server logs, and similar technologies that are necessary to operate, secure, measure, and understand use of the Services. These technologies may remember settings, support authentication and functionality, help us diagnose technical issues, and provide aggregated or operational analytics. You can manage cookies through your browser settings, although disabling certain cookies may affect functionality.

No Sale or Targeted Advertising

AdAction does not sell personal information. AdAction also does not share personal information for cross-context behavioral advertising or process personal information for targeted advertising as those terms are defined under applicable U.S. state privacy laws. We do not disclose website visitor personal information to third parties for their own advertising or independent marketing purposes.

2. How We Use Personal Information

We may use personal information for the following purposes:

• Provide, operate, maintain, and support the Services and customer or partner accounts;
• Administer advertising campaigns and related business operations;
• Perform tracking, attribution, measurement, reporting, reconciliation, and analytics;
• Detect, investigate, prevent, and address fraud, invalid activity, abuse, security incidents, and technical problems;
• Process transactions, invoices, and payments and maintain business records;
• Communicate with customers, partners, users, and prospective customers, including responding to questions and support requests;
• Improve, develop, test, and protect the Services and our business operations;
• Send marketing communications about AdAction where permitted by law and honor communication preferences;
• Comply with applicable law, legal process, regulatory requirements, contractual obligations, and enforce our agreements; and
• Establish, exercise, or defend legal claims and protect the rights, safety, property, and security of AdAction and others.

3. How We Disclose Personal Information

We do not sell personal information or disclose it for cross-context behavioral advertising or targeted advertising. We may disclose personal information in the following limited circumstances:

• Service providers. Vendors that perform services on our behalf, such as hosting, cloud infrastructure, analytics, communications, payment processing, fraud prevention, security, database administration, and other operational support. We require service providers to process personal information only for authorized purposes and subject to appropriate contractual obligations.
• Affiliates. Companies under common ownership or control with AdAction where reasonably necessary for the purposes described in this Privacy Policy.
• Professional advisers. Lawyers, accountants, auditors, insurers, financial advisers, and other professional advisers where reasonably necessary to obtain advice or protect our interests.
• Legal and compliance recipients. Courts, regulators, law-enforcement authorities, government agencies, or other parties where we reasonably believe disclosure is required or permitted by law or necessary to protect rights, safety, security, or property.
• Business transaction participants. Actual or prospective parties and advisers in connection with a merger, acquisition, financing, reorganization, sale of assets, or similar corporate transaction, subject to appropriate confidentiality protections where applicable.
• At your direction. Other parties when you direct us to disclose information or provide consent where consent is required.

4. Customer End-User Data and AdAction’s Role

AdAction provides performance advertising and marketing services to advertisers, publishers, developers, and other business customers. In providing those services, AdAction may receive or process device identifiers, advertising identifiers, IP addresses, click and impression information, attribution and conversion identifiers, transaction or event information, app or device information, in-app event or purchase information, and hashed identifiers.

For some processing activities, AdAction acts solely on behalf of a customer as a service provider, processor, or subprocessor and processes personal information according to that customer’s instructions and applicable contractual terms. For other limited activities—such as tracking and attribution, measurement, fraud prevention, security, compliance, and AdAction’s own legal and business obligations—AdAction may determine the purposes and means of processing and act as an independent controller or business, as applicable. This Privacy Policy applies to personal information AdAction processes in that independent capacity.

5. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services, maintain business and transaction records, comply with legal and contractual obligations, resolve disputes, prevent fraud and abuse, and enforce our agreements. Retention periods vary depending on the nature of the information, the purpose for which it is processed, and applicable legal requirements. We may retain aggregated or de-identified information where permitted by law.

6. Data Security

AdAction maintains reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, use, alteration, disclosure, loss, or destruction. No security measure or method of transmission or storage is completely secure, and we cannot guarantee absolute security.

7. Your Privacy Choices and Rights

Marketing Communications

You may opt out of AdAction marketing emails by using the unsubscribe link in the message or contacting us at privacy@adaction.com. We may continue to send non-promotional communications relating to accounts, transactions, security, legal matters, or the Services.

Cookies

Most browsers allow you to control or delete cookies through browser settings. Disabling certain cookies may affect the operation of the Services.

U.S. State Privacy Rights

Depending on where you live and subject to applicable law, you may have rights to request access to or confirmation of personal information we process about you; obtain a copy of your personal information; correct inaccurate personal information; delete personal information; and appeal a decision regarding a privacy request. Some laws also provide rights to opt out of the sale of personal information, targeted advertising, or certain profiling, and to limit certain uses or disclosures of sensitive personal information.

AdAction does not sell personal information or process it for targeted advertising or cross-context behavioral advertising. Accordingly, there is no sale or targeted-advertising processing from which you need to opt out. Where applicable law requires recognition of a valid universal opt-out mechanism, including Global Privacy Control (“GPC”), we will process the signal as required by law. Because we do not sell personal information or use it for targeted advertising, a GPC signal generally will not change our practices.

To exercise an applicable privacy right, email privacy@adaction.com. We may need to verify your identity and authority before completing a request. Where permitted by law, an authorized agent may submit a request on your behalf. We will not discriminate against you for exercising applicable privacy rights.

California Residents

For purposes of the California Consumer Privacy Act, as amended (“CCPA”), the categories of personal information we may collect are described in Section 1 and may include identifiers; commercial information; internet or other electronic network activity; geolocation information at a general level; and professional or employment-related information. We collect these categories from the sources described in Section 1, use them for the purposes described in Section 2, and disclose them to the categories of recipients described in Section 3.

AdAction does not sell or share personal information as those terms are defined by the CCPA. We do not use or disclose sensitive personal information for purposes that require a right to limit under the CCPA.

8. European, UK, and Swiss Privacy Rights

If European Data Protection Laws apply to our processing of your personal information, you may have rights to access, correct, erase, or restrict processing of your personal information; object to certain processing; receive certain personal information in a portable format; withdraw consent where processing is based on consent; and lodge a complaint with an applicable supervisory authority.

Our legal basis for processing depends on the context. We may process personal information because it is necessary to perform a contract or take steps at your request; to comply with legal obligations; based on our legitimate interests in operating and improving the Services, administering our business, performing measurement and attribution, preventing fraud, maintaining security, and protecting our legal rights, where those interests are not overridden by your rights; or based on consent where consent is required by law.

AdAction Interactive LLC is the controller for personal information covered by this Privacy Policy when AdAction determines the purposes and means of processing. You may contact us using the information in Section 12.

9. International Data Transfers

AdAction is based in the United States, and personal information may be processed in the United States and other countries where AdAction or its service providers operate. Where applicable law requires safeguards for international transfers, we use appropriate transfer mechanisms, which may include the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Addendum or other lawful UK transfer mechanism, and appropriate safeguards for transfers subject to Swiss law.

10. Children’s Privacy

AdAction’s websites, customer portals, and business-facing Services are not directed to children under 13, and we do not knowingly collect personal information directly from children under 13 through those properties. If you believe a child has provided personal information directly to AdAction in violation of applicable law, please contact us at privacy@adaction.com.

11. Third-Party Websites and Services

The Services may contain links to websites, applications, or services operated by third parties. AdAction does not control and is not responsible for the privacy practices of those third parties. We encourage you to review their privacy notices before providing personal information.

12. Contact Us

If you have questions about this Privacy Policy, AdAction’s privacy practices, or would like to exercise an applicable privacy right, please contact us at:

AdAction Interactive LLC
Attn: AdAction Legal Department
Email: privacy@adaction.com

Effective Date: October 6, 2026