AppLovin Legal Information

Content

Effective Date: September 26, 2025

Introduction

This U.S. Multistate Privacy Notice (this “Notice”) supplements the information contained in our Privacy Policy and applies only to individual residents (the “Covered Individual Residents”) of the applicable 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 (the “CCPA”), the Colorado Privacy Act, the Connecticut Data Privacy Act, Oregon Consumer Privacy Law, Utah Consumer Privacy Act, the Virginia Consumer Data Protection Act, and each of their associated regulations, as well as similar applicable state consumer privacy laws that are in effect (collectively, the “State Privacy Laws”).

This Notice addresses the specific disclosure requirements under the State Privacy Laws and provides additional information about how we collect, use, share, and otherwise process Covered Individual Residents’ personal information, the rights of Covered Individual Residents in relation to that personal information, and the ways to exercise those rights. You can find more information and details about AppLovin and our personal information collection and use practices in our Privacy Policy. Unless otherwise indicated, all terms in this Notice have the same meanings as defined in our Privacy Policy or as otherwise defined under the State Privacy Laws.

Collection, Use, and Disclosure of Personal Information

As explained in our Privacy Policy, consumers interact with us in various ways, primarily through advertisements served by AppLovin on behalf of advertisers. We may collect information about you when you use a mobile application, platform, or service that contains the AppLovin SDK, when you interact with e-commerce platforms or merchant websites that embed our pixel, API, or similar technologies, when you interact with our advertising platform in another way, or when your visit our corporate website at www.applovin.com. We encourage you to review the privacy policies of the mobile apps, websites, and platforms you interact with, which may contain additional information regarding their sharing of personal information with AppLovin or other parties.

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 personal information for a business purpose. 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	Disclosure for a Business Purpose
Identifiers, such as IP address and Advertising IDs (IDFA/GAID/Amazon FOSAID) if available.	• You or your device(s) • Publishers • Advertising Partners • Affiliates	• Service Delivery • Delivery of Advertisements • Technical Support • Customer Support • Processing Payments • Analytics • Business Research & Development • Marketing & Promotions • Platform Protection & Fraud Prevention • Compliance with Legal Obligations	• Service Providers • Affiliates • Advertising Partners • Your Specified Recipient(s) • Government Entities/Law Enforcement
Identifiers, such as hashed email addresses and phone numbers (relating to e-commerce services only)	• You or your device(s) • Advertising Partners	• Service Delivery • Delivery of Advertisements • Technical Support • Customer Support • Analytics • Business Research & Development • Platform Protection & Fraud Prevention • Compliance with Legal Obligations	• Service Providers • Your Specified Recipient(s)
Additional Customer Records, such as bank account number or other financial information	• You (only for business users)	• Service Delivery • Technical Support • Customer Support • Processing Payments • Platform Protection • Compliance with Legal Obligations	• Service Providers • Your Specified Recipient(s)
Characteristics of Protected Classifications, such as age or gender	N/A	N/A	N/A
Sensitive Personal Information, such as social security numbers, precise geolocation, or genetic and biometric data*	N/A	N/A	N/A
Commercial Information, such as records of services considered or other purchasing or consuming histories or tendencies	• You or your device(s) • Publishers	• Service Delivery • Delivery of Advertisements • Analytics • Business Research & Development • Platform Protection & Fraud Prevention • Compliance with Legal Obligations	• Service Providers • Your Specified Recipient(s)
Internet or Network Information, such as information regarding interactions with a website, application, or advertisement, or online shopping browser history	• You or your device(s) • Service Providers • Publishers	• Service Delivery • Delivery of Advertisements • Analytics • Business Research & Development • Platform Protection & Fraud Prevention • Compliance with Legal Obligations	• Service Providers • Affiliates • Advertising Partners • Your Specified Recipient(s)
Geolocation Data, such as city or 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) • Publishers • Advertising Partners • Affiliates • Service Providers	• Service Delivery • Delivery of Advertisements • Analytics • Business Research & Development • Platform Protection & Fraud Prevention • Compliance with Legal Obligations	• Service Providers

*AppLovin does not collect or seek to elicit end users’ “sensitive personal information” as defined by the State Privacy Laws. In some cases, we will collect financial account or credit card numbers (for payment-related purposes) from our business customers; however, this information is not used to infer characteristics about those customers as contemplated under the CCPA.

AppLovin does not “sell” your personal 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. However, AppLovin may “share” your personal information for purposes of serving you with personalized ads or content, otherwise known as “interest-based advertising” or “cross-context behavioral advertising.” Under the CCPA and other State Privacy Laws that expansively define or interpret “sell,” certain advertising and analytics activities may constitute a “sale.” For example:

When you use a mobile application, the publisher of that application may decide to serve you with interest-based ads. If that application embeds AppLovin’s software, we’ll send a bid request that contains certain of your device information (if available) to our advertising demand side partners to enable their ads to be served to you based on your interests (which they derive independently or from other third-party advertising partners). Under the CCPA and other State Privacy Laws, passing device data in a bid request to our demand side partners is “sharing” (under the CCPA) and may be a “sale” of personal information.

Data Retention

As explained in our Privacy Policy, we retain data collected through the Services as long as we continue to receive updated information from your device, or until you request deletion, whichever occurs first. If we do not receive any updated information through the Services for a continuous period of 2 years, data is automatically purged from our systems. 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.

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/Portability	Under the State Privacy Laws, you have the right to obtain confirmation regarding whether we are processing your personal information and to access that personal information and, in some cases, information about the third parties who may receive such personal information. You also have the right to access that personal information in a portable, readily usable format, unless not technically feasible to provide in such a format. With respect to the CCPA’s right to access, you have the right to request the following: (a) the specific pieces of personal information the business has collected about you and (b) the categories of personal information collected, the sources of collection, the business/commercial purpose for collecting or “selling/sharing” personal information, and the categories of third parties to whom the business discloses personal information.
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 or Targeted Advertising	AppLovin may disclose or otherwise process 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.” In certain circumstances, you have the right to opt-out of “sales” or “sharing” of your personal information (i.e., Identifiers and Internet/Network Information to Advertising Partners) for purposes of serving you with targeted ads or content, otherwise referred herein as “cross-contextual behavioral advertising” or “targeted advertising.”
Non-Discrimination	You have the right to exercise the rights conferred on you by the State Privacy Laws without discrimination.
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.
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 Profiling in Furtherance of Decisions that Produce Legal or Similarly Significant Effects	In certain circumstances, you have the right to opt-out of the use of your personal information for profiling in furtherance of decisions that produce legal or similarly significant effects.

How to Exercise Your Privacy Rights

To exercise your rights to know and access your personal information or to request deletion of your personal information, you have the following options (listed according to the types of interaction you may have with AppLovin):

For Users of Mobile Games and/or Other Applications, Platforms, or Services Containing the AppLovin SDK or Similar Technologies

To access or delete the personal information that AppLovin may have about you from the mobile games or other applications, platforms, or services that you use (e.g., personal information used as part of our Advertising Services), you may download the AppLovin Privacy Management Application from the Apple or Google Play Stores:

To exercise your right to opt-out of “sales/shares” or “targeted advertising” with respect to AppLovin’s Advertising Services, you have the following options:

Opt-Out through AppLovin Ads. AppLovin allows you to opt-out of all interest-based advertising served by AppLovin through the “i” or “Learn more about ad preferences” link available on the face of an ad served by AppLovin. Once you click on the link, you will see a button to “Opt-Out of Interest-Based Advertising.”
Opt-Out through Device-Level Choices. In addition, if you do not want to receive interest-based advertisements, you can limit the collection of certain information through your device’s settings. Detailed instructions on how to change these device settings can be found in the “Manage Your Privacy Choices” section of our Privacy Policy and in the instructions available here.

Please know that opting out of targeted advertising does not mean that you will not receive advertising. You may still receive ads, but those ads may be less relevant to your interests.

To exercise any other rights that you may have under the State Privacy Laws, or if you have any questions regarding any response to your request, please contact our Data Protection Officer using the information in the “Contact Us” section of our Privacy Policy.

For Our Website Visitors

To control data collection and sharing via certain cookies or other data collection technologies on our website, you can click “Cookie Settings” in the footer of our website. In addition, you may follow the steps outlined in the “Cookies and Other Similar Technology” section of our Privacy Policy. To access or delete information that you have manually submitted to us, please contact our Data Protection Officer using the information in the “Contact Us” section of our Privacy Policy.

For Our Customers and Business Contacts

Please contact our Data Protection Officer using the information in the “Contact Us” section of our Privacy Policy. Please provide enough information about you and your request for our Data Protection Officer to be able to identify your information in our records.

* * * *

Please note that requesting to exercise your rights through us will not bear on the personal information processed about you by our third-party partners and customers, including the publishers or other third parties to whom you provide information. If you wish to exercise your rights with respect to these third parties, please submit a request with each party directly.

Children’s Privacy

As explained in our Privacy Policy, AppLovin does not knowingly collect personal information from, or serve advertisements to, children as defined and required by the State Privacy Laws. If you believe we have served an advertisement to a child or might have any personal information from or about a child, or if you believe a mobile application in which an AppLovin-served advertisement appeared may be designed for, directed to, or pass personal information knowingly from, children, please contact us via email at [email protected].

Appointment of an Authorized Agent

In certain circumstances, you may appoint an authorized agent to exercise any rights that you may have on your behalf. To the extent permitted under law, we will take steps to verify the identity of the person seeking to exercise their rights and to verify that the corresponding agent has been authorized to make a request on that person’s behalf, such as by providing us with a signed written authorization.

Data Access and Deletion Transparency Report

Our annual transparency report shows the number of data access and deletion requests we received last year and how long it typically takes us to fulfill those requests.

Type of Request	Requests Completed*	Average Time to Substantively Respond
Requests to Know and Access	1250	Less than 1 day (successful requests processed automatically)
Requests for Deletions	7392	Less than 1 day (successful requests processed automatically)

*The Data Access and Deletion Transparency Report includes data for US-based users, who submitted requests via the AppLovin Privacy Management App. The AppLovin Privacy Management Application processes all requests automatically, except where the requests cannot be verified.

Updates or Amendments to this Notice

As explained in our Privacy Policy, we may make changes to this Notice from time to time. If we make any changes, we will update the “Effective Date” posted at the top of this Notice. We encourage you to review this Notice periodically.

How to Contact Us

You can find our contact information in the “Contact Us” section of our Privacy Policy.

AppLovin Legal Information

Content

Effective Date: September 22, 2025

AppLovin Corporation (“AppLovin,” “we,” “us,” or “our”) operates a suite of tools for app developers and other businesses to automate and optimize the marketing and monetization of their platforms, products, or services by enabling the placement of different types of advertisements on digital properties including mobile apps, websites, and connected TV devices (collectively, the “Advertising Services” or “Services”). As explained below, consumers interact with us in various ways, primarily through advertisements served by AppLovin on behalf of advertisers.

The AppLovin Privacy Policy (this “Privacy Policy”) explains how we collect, use, and share information through our Services and advertising platform, and our corporate website at www.applovin.com (the “Website”), as well as your choices related to that information.

Our Advertising Services

This section describes the information we collect, use, and share through our Advertising Services.

General Information Collection and Use

If you are a consumer who downloads and uses an application which contains the AppLovin SDK or otherwise interacts with the Services through advertisements served within a digital property, we may collect certain information, including the following:

Device, App, and Browser Data

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, and theme;
Carrier;
Name and properties of mobile application through which a consumer interacts with the Services;
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;
HTTP header information;
Advertising IDs (IDFA/GAID/Amazon Advertising ID);
Vendor IDs (IDFV);
App Set IDs; and
Advertising and tracking preferences and restrictions.

Advertisers (through the advertiser itself or through a third party service provider on behalf of such advertiser) may also share transactional or other “event” 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.

Information Collection and Use Specific to e-Commerce Ads Only

If you are a consumer who interacts with the Services through an e-commerce platform or merchant website, we may collect certain additional information that you provided to the e-commerce platform or merchant (either through our SDK or pixel or through a third party’s API or other similar technologies), including the following:

User IDs;
Shopping browsing behavior (e.g., views) and search history;
Records of products purchased or considered (e.g., added to cart, check out);
Purchasing histories;
Hashed email addresses and phone numbers; and
Information regarding user interactions with advertising partners and their merchant partners’ sites and advertisements.

How We Collect Your Information

This information may be collected automatically across mobile apps and devices or received from third parties across different technologies over time. We may also combine information we collect with other information we derive through analytical techniques and we will use that combined information to provide the Services.

How We Use Your Information

We generally use the information we collect to:

Deliver the Services, maintain, and improve them, including our AI-powered advertising technology, and research and develop new ones;
Promote safety, security, and integrity of Services;
Provide measurement, analytics, and reporting; and
Comply with legal and regulatory obligations.

We use AI-powered advertising technology to help us improve our advertising products and Services and serve ads that are relevant and interesting to you. We use it in ways that do not produce legal or similarly significant effects on you (for example, we may use such technology to provide an ad for a product you may be interested in or to reorder how advertisements might appear when you visit a digital property such as a mobile app or a website).

Information Sharing

We may share information we collect or derive with third parties in the following contexts:

Service Providers. We transfer information to service providers and other partners who support our business, such as those that provide technical infrastructure services, analyze how our Services are used, measure the effectiveness of ads and services, provide customer service, or facilitate 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.
Affiliates. We may share information within the AppLovin family of companies for purposes consistent with this Privacy Policy.
Advertising Partners. We share information with our third-party advertising partners, including advertisers, ad networks, exchanges, demand side platforms, merchants, other advertising partners (who aggregate their own demand sources), and ad optimization and measurement/attribution partners (e.g., mobile measurement partners or “MMPs”) to provide our clients with Advertising Services. This information may be used by such third-party partners to measure how effective ads are, show advertisements to end users for products and services that are more likely to appeal to them (a practice known as interest-based advertising or behavioral advertising), and to undertake analytics to analyze traffic and other ad activity to improve the advertising experience.

Unless otherwise noted in our partner list, each AppLovin advertising partner is an independent controller of your data. You can view a list of AppLovin advertising partners with whom we share your data here, current as of the date listed at the top of that page.

If you do not want to receive “interest-based advertisements,” please see the “Manage Your Privacy Choices” section below. If you are located in the European Union, UK, or Switzerland, you may also see the “Additional Provisions for EU/UK/Swiss Individuals” section below for more options. If you are an individual resident of the U.S. states that have enacted comprehensive consumer privacy laws, you may also review the “U.S. Multistate Privacy Notice” section below for more options.

Please note that the practices of our third-party advertising partners delivering advertisements through our Services are subject to those partners’ own privacy policies.
Regulatory or Legal Requirements. We may disclose information to governmental regulatory authorities as required by law, including for tax or accounting purposes, in response to their requests for such information or to assist in investigations. We may also disclose personal information to third parties in connection with claims, disputes, or litigation, or when otherwise required by law or court order.
Safety and Terms Enforcement. We may disclose information if we determine, in our sole discretion, that its disclosure is necessary to protect the health, safety, or rights of you or any other person, protect against fraud, or enforce our legal rights, including contractual commitments made to us by third parties.
Business Transfers. We may disclose personal information as part of an organizational business transaction, such as a merger, acquisition, joint venture, financing, or sale of organizational assets, and may transfer personal information to a third party as one of the business assets in such a transaction. We may also disclose personal information in the event of insolvency, bankruptcy, or receivership.

Manage Your Privacy Choices:

To limit collection of information from mobile devices, please visit your device’s settings to set the “Limit Ad Tracking” or other similar features on your device. Additionally, you may opt-out of interest-based advertising within ads served by AppLovin; for detailed instructions, see How AppLovin Shows You Ads. You can also make choices about data collection for certain companies by visiting an industry consumer choice platform such as the NAI (https://optout.networkadvertising.org/) or DAA (https://optout.aboutads.info/). You may still receive ads after limiting processing of your information for interest-based advertising but those ads may be less relevant to your interests.

To access or delete the data collected by AppLovin from your device, you may download the AppLovin Privacy Management Application from the Apple or Google Play Stores:

By navigating through the tabs in the AppLovin Privacy Management Application, you can erase the personal information that AppLovin may have collected about you or request a copy of that personal information. If you encounter technical issues with the app, please contact us via email at [email protected].

Children’s Privacy

We do not knowingly collect personal information from, or serve advertisements to, children as defined and required by applicable laws. If you believe we have served an advertisement to a child or might have any personal information from or about a child, or if you believe a mobile application in which an AppLovin-served advertisement appeared may be designed for, directed to, or pass personal information knowingly from, children in violation of our policies, please contact us via email at [email protected].

Data Security and Retention

We implement reasonable measures to help secure the information we collect through the Services. We retain data collected through the Services as long as we continue to receive updated information from your device, or until you request deletion, whichever occurs first. If we do not receive any updated information through the Services for a continuous period of 2 years, data is automatically purged from our systems. 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.

[END OF ADVERTISING SERVICES-SPECIFIC PROVISIONS]

Our Website

This section describes the information we collect, use, and share through our Website.

Cookies and Other Similar Technology

The Website uses cookies, pixels, or other similar technology to collect information for various purposes, including interest-based advertising. This information may include your IP address, device identifier, browser type, device type, the date and time of your visit, and the areas of the Website you visit. To learn more about and manage the cookies on this Website, please click “Cookie Settings” in our Website footer. You may also be able to limit the use of cookies through your browser settings. Note that certain parts of the Website may not function properly without cookies. Additionally, you may still receive ads after limiting processing of your information for interest-based advertising but those ads may be less relevant to your interests. If you erase your cookies, reset your device identifier, or use different browsers or devices, you may need to make your choices again.

We 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.

Additional Information Collection for Business Account Owners

When you register with AppLovin to use our Services, you may provide us with personal information such as your name, email address, phone number, mailing address, user name, and password. You may also provide us with payment information when you submit or receive a payment or other information when you complete the online forms available on the Website. We may also acquire information from other trusted sources to update or supplement the information that you voluntarily provide to us or that we collect automatically.

How We Use Your Information

We may use the information we collect in connection with the Website for various purposes, including:

To communicate with you, for example through newsletters or with other information about our products and services;
To operate and improve the Website and our Services;
To customize the Website;
For analytics and research;
For marketing purposes; and
For purposes disclosed at the time of collection.

We may share information we collect in connection with the Website in the following contexts:

With your consent;
For advertising and marketing purposes;
In response to a subpoena, court order, or other legal process;
To protect our rights and the rights of others;
With our affiliates;
With service providers that help us operate the Website and Services;
As part of a sale, merger, or acquisition, including at bankruptcy; and
For purposes disclosed at the time of collection.

Links to Other Websites

The Website may provide links to other websites or other digital properties that we do not control. We encourage you to review the privacy policy of those digital properties that you may visit.

Updating Information

You can update the personal information you provide to us by correcting, updating, or deleting the information associated with you via your AppLovin account. To add, modify, remove, or request access to the personal information about you that we hold, please see the “Contact Us” section below.

Your Email Marketing Choices

If you no longer wish to receive marketing-related emails from us on a going-forward basis, you may opt out of receiving these emails by clicking “Unsubscribe” at the bottom of any marketing email you receive from us or by emailing us at [email protected].

Children

Our Website is not intended for use by children as defined and required by applicable law. We do not knowingly collect personal information from children through the Website. If you believe we might have any personal information from or about a child, please contact us via email at [email protected].

Data Security and Retention

We have implemented reasonable physical, technical, and administrative security measures for the Website to help protect information we collect and store.

For detailed information regarding retention associated with cookies on the applovin.com domain, please click “Cookie Settings” in our Website footer to learn more.

We retain other information such as customer contact and payment information in our systems for as long as necessary as permitted by law to comply with our legal obligations, resolve disputes, and enforce our agreements.

[END OF WEBSITE-SPECIFIC PROVISIONS]

Additional Provisions for EU/UK/Swiss Individuals

If you are located in the European Union, United Kingdom, or Switzerland, the following additional provisions apply to you.

Data Privacy Framework

AppLovin complies with the EU-U.S Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.

AppLovin has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. AppLovin has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

If you are an EU, UK, or Swiss individual, where we transfer your personal data to third party servicer providers (see above) who perform services for us or on our behalf, we are responsible for the processing of that data by them and shall remain liable if they process your personal data in a manner inconsistent with the DPF Principles, unless we are not responsible for the event giving rise to the damage.

With respect to personal data received or transferred pursuant to the Data Privacy Framework, AppLovin is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, AppLovin may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, AppLovin commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact AppLovin at [email protected]. AppLovin refers unresolved complaints to TRUSTe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. These dispute resolution services are provided at no cost to you.

For complaints regarding DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found on the official DPF website.

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 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.

Otherwise, 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.

If personal data covered by this Privacy Policy is to be used for a new purpose that is materially different from that for which the personal data was originally collected or subsequently authorized, or is to be disclosed to a non-agent third party in a manner not specified in this Privacy Policy, we will provide you with an opportunity to choose whether to have your personal data so used or disclosed. Requests to opt out of such uses or disclosures of personal data should be sent to us as specified in the “Contact” section below. Certain personal data, such as information about medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, is considered “Sensitive Information.” AppLovin does not collect or seek to elicit “Sensitive Information.”

For questions about data processing, please contact our Data Protection Officer. Visit the “Contact” section below for contact information.

Your Rights

If you are an individual in the EU, UK, or Switzerland, 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, please contact us at the email address set forth in the “Contact Us” section below. Our Data Protection Officer can also be reached at this email address. 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.

In certain circumstances, you may appoint an authorized agent to exercise any rights that you may have on your behalf. If you choose to exercise any rights through an authorized agent, you will need to verify your identity directly with us before we can process any requests. In addition, we will need written documentation demonstrating the authorized agent’s authority to act on your behalf.

Additionally, you have the right to lodge a complaint against us. To do so, contact the supervisory authority in your country of residence.

EU and UK Privacy Representatives

We have appointed Prighter Group as our privacy representatives in the EU and UK. You can contact us through our privacy representatives at the following addresses:

For residents of the EU:
PrighterGDPR-Rep by Maetzler Rechtsanwalts GmbH & Co KG
c/o AppLovin Corporation
Kriegerstraße 44
30161 Hannover
Germany

For residents of the UK:
PrighterUK-Rep by Prighter Ltd.
c/o AppLovin Corporation
20 Mortlake Mortlake High Street
London, SW14 8JN
United Kingdom

Additional information regarding our privacy representatives can be found at the following link: https://prighter.com/q/19826057144.

[END OF EU/UK/SWISS SPECIFIC PROVISIONS]

U.S. Multistate Privacy Notice

Additional provisions for individual residents of the U.S. states that have enacted comprehensive consumer privacy laws are included in our U.S. Multistate Privacy Notice, which explains how those residents may exercise their privacy rights.

Policy Changes

We may, in our sole discretion, make changes to this Privacy Policy from time to time in order to accommodate new technologies, industry practices, regulatory requirements, or for other purposes. If we make any changes, we will update the “Effective Date” posted at the top of this Privacy Policy. If we make any material changes, we may notify you by email (sent to the email address specified in your account) or by means of a notice on the Website prior to the change becoming effective. We encourage you to review this Privacy Policy periodically to ensure that you understand how we collect, use, and share information.

Any changes to this Privacy Policy will become effective when the revised Privacy Policy is posted on the Website. By continuing to use the Website or Advertising Services following such changes, you are agreeing to accept the terms of the revised Privacy Policy.

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 or our Data Protection Officer via email at [email protected].

Please be sure to include your relevant account information in any correspondence to us. This will help ensure that we can respond to your inquiry in a timely manner.

If you have a customer care issue, please visit Axon Support Center.

AppLovin Legal Information

Content

Effective Date: September 22, 2025

This AppLovin Platform Data Processing Agreement (“DPA”) is incorporated into and is subject to the AppLovin Terms of Use Agreement available at https://legal.applovin.com/terms/ or other applicable offline agreement (the “Agreement”) between AppLovin Corporation (“AppLovin”) (even if the Agreement is with a different AppLovin Affiliate) and User. To the extent you are using the Services, you shall be deemed to have accepted this DPA upon acceptance or execution of the applicable Agreement.

SCOPE
1. The Parties agree to enter into this DPA for the purposes of ensuring compliance with applicable Data Protection Laws. User enters into this DPA on behalf of itself and on behalf of its authorized Affiliates. AppLovin may receive Personal Data through User’s use of the Services and, in consideration of the mutual obligations set out herein, the Parties agree to comply with the following provisions with respect to any Personal Data Processed through the Services. Except as modified below, the terms of the Agreement shall remain in full force and effect.
DEFINITIONSIn addition to the terms defined in the Agreement and above, the following terms shall have the following meanings for the purposes of this DPA:
1. “Adequate Jurisdiction” means a country which ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data, as determined by the European Commission in the case that GDPR applies, and as determined by the UK Information Commissioner’s Office in the case that the UK GDPR applies.
2. “Affiliates” means an entity that directly or indirectly controls, is controlled by, or is under common control with, a Party.
3. “Approved Addendum” means the template addendum (version B.1.0) issued by the United Kingdom International Commissioner’s Office (ICO) and laid before the United Kingdom Parliament in accordance with s119A of the Data Protection Act 2018 on 2 February 2022, as it is revised under Section 18 of such addendum.
4. “CCPA” means the California Consumer Privacy Act of 2018, Cal Civ. Code §1798.100 et seq., and all implementing regulations, as amended from time to time, such as by the California Privacy Rights Act of 2020 (“CPRA”).
5. “Data Protection Laws” means EU Data Protection Law, the CCPA, the Brazilian General Personal Data Protection Law, No. 13,709/2018 (the “LGPD”), and any other legislation protecting natural persons’ right to privacy with regard to the processing of Personal Data to the extent applicable to a Party’s Processing of Personal Data under the Services.
6. “Data Subject Rights” means the rights granted to Data Subjects under Data Protection Laws.
7. “EU Data Protection Law” means the GDPR, the e-Privacy Directive and national implementing legislation and the Swiss Federal Data Protection Act.
8. “GDPR” means the EU General Data Protection Regulation 2016/679 of the European Parliament and of the Council (“EU GDPR”) and, where applicable, the “UK GDPR” as defined in the Data Protection, Privacy and Electronic Communications (Amendment Etc.) (EU Exit) Regulations 2019.
9. “Member State” means a member state of the European Economic Area, together with Switzerland and the United Kingdom.
10. “SCCs” means (a) with respect to data transfers from the European Union to third countries that are not deemed adequate jurisdiction by the European Commission, Module 1 (controller to controller) of the Standard Contractual Clauses annexed to Commission Implementing Decision (EU) 2021/914 (the “EU SCCs”); (b) with respect to data transfers from the United Kingdom, Module 1 (controller to controller) of the EU SCCs as further amended by Part 2: Mandatory Clauses of the Approved Addendum (the “UK Mandatory Clauses”), together with any other necessary conforming changes to the EU SCCs (collectively, the “UK SCCs”); and (c) any updated, revised, or separate clauses relating to data transfer requirements of the GDPR issued from time to time by the European Commission, UK Information Commissioner’s Office, any other applicable data protection authority, or other body with competent authority and jurisdiction.
11. “Shared Personal Data” means Personal Data Processed by a Party to the extent such Party received that Personal Data from the other Party (that other party, the “Sharing Party” under this definition) in connection with the performance of the Agreement. For the avoidance of doubt, a Party is also deemed to “receive” Personal Data from a Sharing Party where the Sharing Party grants access to such Personal Data to the receiving Party.
12. “Transparency Notices” has the meaning given to it in clause 3.2.1.
13. The terms “Controller,” “Process,” “Processor,” “Data Subject,” and “Personal Data,” shall have the meanings given in Data Protection Laws. To the extent Data Protection Laws use different terms to cover concepts similar to those covered under the aforementioned bold terms in this Section 2.13, then “Controller,” “Process,” “Processor,” “Data Subject,” and “Personal Data” shall have the meaning assigned to those different terms under such Data Protection Laws.
DATA PROCESSING; INDEPENDENT CONTROLLERS
1. AppLovin and User: (a) are independent Controllers with regard to the Shared Personal Data; and (b) will individually determine the purposes and means of its Processing of Personal Data.
2. Each Party shall, with respect to the Processing of any Shared Personal Data, comply with Data Protection Laws, including as follows:
  1. each Party shall provide all applicable notices, disclosures, and privacy policy to Data Subjects as required under Data Protection Laws for the lawful Processing by it of Shared Personal Data (“Transparency Notices“). User shall disclose its use of the Services, its sharing or otherwise making available of Personal Data with/to AppLovin, and how AppLovin Processes Personal Data in its Transparency Notices. For example, for Users that have embedded AppLovin advertising Services in their mobile applications or websites, this can be done by including the following language in the User’s Transparency Notices: “We work with AppLovin to deliver ads. For more information about AppLovin’s collection and use of your information, visit: /”;
  2. each Party shall provide all required mechanisms for, and give effect to, applicable Data Subject Rights pursuant to Data Protection Laws and respond to inquiries by governmental authorities;
  3. neither Party shall Process the Shared Personal Data for any purpose other than as set out in its Transparency Notice and unless such Processing is also authorized under Data Protection Laws and the Agreement;
  4. each Party shall ensure that all of its employees engaged in the Processing of such Shared Personal Data act consistently with this DPA;
  5. each Party shall implement technical and organisational security measures to prevent (i) the accidental, unlawful, or unauthorized destruction, loss, alteration, or disclosure of, or access to, Shared Personal Data or (ii) any other security incident that amounts to a “personal data breach” (as such term or similar term, such as “breach of the security system” or “data breach,” is defined under Data Protection Laws) of Shared Personal Data (in either case of (i) and (ii), a “Data Breach”); and
  6. each Party agrees that any agreement with a subprocessor shall comply with the Data Protection Laws.
3. Each Party shall in particular, unless prohibited under applicable law, notify the other without undue delay (i) of any requests to exercise Data Subject Rights received by that Party regarding the Shared Personal Data, to the extent such notices are required under Data Protection Law; (ii) about regulatory inquiries involving the Processing of Shared Personal Data, and (iii) any Data Breach involving the Shared Personal Data to the extent resulting in material destruction, loss, alteration, or disclosure of, or access to, that Shared Personal Data.
4. User represents and warrants it has provided (and shall maintain) all required notices in compliance with Section 3.2.1 and obtained all necessary permissions and consents required under the Data Protection Laws from the relevant Data Subjects on behalf of AppLovin to lawfully permit AppLovin to Process Personal Data as contemplated in the Agreement and Applicable Data Protection Laws.
5. Where consent is the lawful basis for Processing Personal Data or otherwise required for the use of the Services, User represents and warrants that it shall, at all times, make available, maintain, and make operational on the User’s properties: (i) a mechanism for obtaining such consent from Data Subjects in accordance with the requirements of the Data Protection Laws; and (ii) a mechanism for Data Subjects to withdraw such consent (opt-out) in accordance with the Data Protection Laws.
6. With respect to the CCPA, (i) the Shared Personal Data is disclosed to AppLovin for the limited and specified purposes of enabling AppLovin (or its demand partners) to bid on advertising inventory, serve Advertisements in connection with the Services, and optimize the Services, as further set forth in AppLovin’s Transparency Notices; (ii) AppLovin shall comply with the CCPA, including by providing the same level of privacy protection as required of Businesses under the CCPA; (iii) User may take reasonable and appropriate steps to ensure that AppLovin Processes Shared Personal Data in a manner consistent with User’s obligations under the CCPA; (iv) AppLovin shall notify User promptly after AppLovin makes a determination that it can no longer meet its obligations under the CCPA; and (v) User may, upon notice, take reasonable and appropriate steps to stop and remediate the unauthorized Processing of Shared Personal Data.
7. If User qualifies as a “foreign party” as defined in 28 CFR Part 202 (or similar laws in applicable jurisdictions), User represents and warrants that it will not sell, provide access to, or otherwise share or attempt to share any data provided to User pursuant to its use of the Services to “countries of concern” or “covered persons” as defined in 28 CFR Part 202. If User knows or suspects that a country of concern or covered person has gained access to any data provided to User pursuant to its use of the Services, the User represents and warrants that it will immediately notify AppLovin and take other appropriate steps required under applicable laws.
GENERAL
1. In the event of any conflict or discrepancy between the SCCs, the Agreement, and this DPA, the following order of precedence will apply: (i) the SCCs, (ii) this DPA, and (iii) the Agreement.
2. This DPA does not alter the limitations of liability set out in the Agreement.
3. This DPA will become effective on the date User has accepted the Agreement or the date on which the User started to use the Services. This DPA will terminate simultaneously and automatically upon the termination or expiration of the Agreement.
4. To the extent required by Data Protection Law, this DPA will be governed by the laws of the applicable jurisdiction. In all other cases, this DPA shall be governed by the laws of the jurisdiction set forth in the Agreement.
INTERNATIONAL TRANSFERS
1. The Parties agree that the SCCs shall apply to the transfer of, including access to, Shared Personal Data:
  1. in the case of a transfer from User to AppLovin, where the Processing of the Shared Personal Data by the User is subject to EU Data Protection Law or the LGPD; or
  2. in the case of a transfer from AppLovin to User, where:
    - the User is not established in an Adequate Jurisdiction;
    - the Processing of the Shared Personal Data is subject to EU Data Protection Law or the LGPD or AppLovin is otherwise contractually required to enter into the SCCs.
2. For the purposes of the SCCs:
  1. Annex 1.A (List of Parties) shall be deemed to incorporate the information in Schedule I;
  2. Annex 1.B (Description of Transfer) shall be deemed to incorporate the information in Schedule III;
  3. Annex 1.C (Competent Supervisory Authority) shall be deemed to refer to the supervisory authority identified in Schedule II;
  4. Annex II (Technical and Organisational Measures) shall be deemed to incorporate the information in Schedule II;
  5. The optional language within clause 7 of the SCCs does not apply;
  6. The optional language within clause 11(a) of the SCCs does not apply;
  7. Pursuant to clause 17, the SCCs will be governed by the laws of Germany;
  8. Pursuant to clause 18(b) of the SCCs, the Parties shall resolve disputes under the SCCs before the courts of Germany;
  9. In relation to Table 4 referenced in the UK Mandatory Clauses, neither Party will be entitled to terminate the Approved Addendum in accordance with clause 19 of the UK Mandatory Clauses; and
  10. For data exporters established within Brazil (for purposes of transfers of Shared Personal Data under the LGPD), the SCCs shall be governed by the laws of the Federative Republic of Brazil. Further, for such transfers under the LGPD, the applicable Data Protection Law shall be understood as the LGPD and the supervisory authority is the National Data Protection Authority in Brazil (ANPD).

SCHEDULE I

PARTIES

Contractual party and Role	Address of the party, contact person’s name, position and contact details and, where applicable, of its data protection officer and/or representative in the EU	Activities relevant to the data transferred under these Clauses
AppLovin (Controller)	AppLovin CorporationAddress: 1100 Page Mill Road, Palo Alto, CA 94304 USAE-mail: [email protected]	Personal Data is transferred to AppLovin from the User in the course of providing the Services.
User (Controller)	As specified in the Agreement.	Personal Data that is made available to AppLovin in connection with the use of the Services by the User.

SCHEDULE II

SCCS

Information deemed incorporated into the SCCs
Data exporter	User is the data exporter to the extent User provides and Processes Personal Data of EU and UK Data Subjects in connection with the use of the Services. AppLovin is the data exporter to the extent AppLovin transfers Personal Data of EU and UK Data Subjects to User in connection with the Services.
Data importer	AppLovin is the data importer to the extent User qualifies as data exporter according to what is set out above. User is the data importer to the extent AppLovin is the data exporter according to what is set out above.
Annex I.A	List of Parties: Relevant information regarding “Data exporter” and “Data importer” under this Schedule I and Schedule II are incorporated by reference herein.
Annex I.B	Description of Transfer: Relevant information from Schedule III below is incorporated by reference herein.
Annex I.C	Competent Supervisory Authority: The competent supervisory authority shall be determined based on the situation applicable to the data exporter under clause 13 of the Model Clauses (e.g., if the data exporter is established in an EU member state, or falls under GDPR Article 3(2) and has an appointed representative under GDPR Article 27(1), or falls under GDPR Article 3(2) and has not appointed a representative under GDPR Article 27(1)), except that, in the case of the UK SCCs, the competent supervisory authority under the UK SCCs will be the UK Information Commissioner.
Annex II	Technical and Organisational Measures: Data importer will implement and maintain appropriate administrative, physical, and technical safeguards for the protection of the security, confidentiality and integrity of Personal Data uploaded to the Services. Where AppLovin acts as the data importer, those measures shall be set forth in an AppLovin security statement. Data importer will make that statement available to data exporter upon request.

SCHEDULE III

DESCRIPTION OF THE TRANSFER

Categories of data subjects whose data is transferred

The personal data transferred concern the following categories of data subjects:

Individuals who are end-users of User’s digital property (including mobile application(s), websites, and connected TV devices, and e-commerce platforms) (each, an “End User”).
Individuals who are User’s marketing and business contacts.
Individuals whose navigation of a digital property such as a mobile application or website has triggered an advertising bid request.
Individuals who are User’s employees, agents, or representatives in AppLovin’s online platform.

Categories of data transferred

The personal data transferred concern the following categories of data:

Mobile device advertising identifiers (e.g., IDFA/Google Ad ID, IP address);
Device data such as make, model, operating system, device properties and settings, coarse location data;
Click attribution data and transactional data;
Business contact and billing information (e.g., name, email address, billing address, telephone number, VAT number, bank account number to the extent considered personal data); and
Additionally, for End User’s of User’s e-commerce platform or merchant website and individuals who interact with e-commerce ads:
- User IDs;
- Shopping browsing behavior (e.g., views) and search history;
- Records of products purchased or considered (e.g., added to cart, check out);
- Purchasing histories;
- Information regarding user interactions with advertising partners and their merchant partners’ sites and advertisements; and
- Hashed phone numbers and email addresses, if applicable.

Sensitive data transferred (if applicable)

The personal data transferred concern the following categories of sensitive data:

None.

The frequency of the transfer

In the case that AppLovin and the User agree to Services embedded on a digital property such as live mobile application(s), the transfer will take place in real time every time an end–user accesses and navigates the digital property(-ies).

Nature of the Processing and Purpose of the transfer(s) and further Processing

The Personal Data is Processed for the purpose of providing the Services in accordance with the Agreement, including all permissible purposes set forth in the respective data importer’s Transparency Notice.

The period for which the personal data will be retained, or, if that is not possible, the criteria used to determine that period

AppLovin retains an End User’s Personal Data collected through the Services until AppLovin stops receiving updated information from the End User’s device for a continuous period of two (2) years, or until the End User requests deletion – whichever occurs first.

For transfers to (sub-)processors, also specify subject matter, nature and duration of the Processing

The Personal Data transferred may be disclosed only to the following recipients or categories of recipients:

Service providers that AppLovin uses to provide the Services and those described in its Transparency Notice.
Service providers that User uses to implement, operate, and optimize the Services and those described in its Transparency Notice.

The duration of Processing will align with the data retention period described above.

AppLovin Legal Information

Content

Effective Date: July 3, 2025

This AppLovin Demand Partner Data Processing Agreement (“DPA”) is incorporated into and is subject to the AppLovin Terms of Use Agreement available at https://legal.applovin.com/terms/ or other applicable offline agreement (the “Agreement”) between AppLovin Corporation (“AppLovin”) (even if the Agreement is with a different AppLovin Affiliate) and User. To the extent you are using the Services, you shall be deemed to have accepted this DPA upon acceptance or execution of the applicable Agreement.

SCOPE
1. The Parties agree to enter into this DPA for the purposes of ensuring compliance with applicable Data Protection Laws. User enters into this DPA on behalf of itself and on behalf of its authorized Affiliates. AppLovin may disclose Personal Data through User’s use of the Services and, in consideration of the mutual obligations set out herein, the Parties agree to comply with the following provisions with respect to any Personal Data processed in connection with the Services. Except as modified below, the terms of the Agreement shall remain in full force and effect.
DEFINITIONS In addition to the terms defined in the Agreement and above, the following terms shall have the following meanings for the purposes of this DPA:
1. “Adequate Jurisdiction” means a country which ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data, as determined by the European Commission in the case that GDPR applies, and as determined by the UK Information Commissioner’s Office in the case that the UK GDPR applies.
2. “Affiliates” means an entity that directly or indirectly controls, is controlled by, or is under common control with, a Party.
3. “Approved Addendum” means the template addendum (version B.1.0) issued by the United Kingdom International Commissioner’s Office (ICO) and laid before the United Kingdom Parliament in accordance with s119A of the Data Protection Act 2018 on 2 February 2022, as it is revised under Section 18 of such addendum.
4. “CCPA” means the California Consumer Privacy Act of 2018, Cal Civ. Code §1798.100 et seq., and all implementing regulations, as amended from time to time, such as by the California Privacy Rights Act of 2020 (“CPRA”).
5. “Data Protection Laws” means EU Data Protection Law, the CCPA, the Brazilian General Personal Data Protection Law, No. 13,709/2018 (the “LGPD”), and any other legislation protecting natural persons’ right to privacy with regard to the processing of Personal Data to the extent applicable to a Party’s Processing of Personal Data in connection with the Services.
6. “Data Subject Rights” means the rights granted to Data Subjects under Data Protection Laws.
7. “EU Data Protection Law” means the GDPR, the e-Privacy Directive and national implementing legislation and the Swiss Federal Data Protection Act.
8. “GDPR” means the EU General Data Protection Regulation 2016/679 of the European Parliament and of the Council (“EU GDPR”) and, where applicable, the “UK GDPR” as defined in the Data Protection, Privacy and Electronic Communications (Amendment Etc.) (EU Exit) Regulations 2019.
9. “Member State” means a member state of the European Economic Area, together with Switzerland and the United Kingdom.
10. “SCCs” means (a) with respect to data transfers from the European Union to third countries that are not deemed adequate jurisdiction by the European Commission, Module 1 (controller to controller) of the Standard Contractual Clauses annexed to Commission Implementing Decision (EU) 2021/914 (the “EU SCCs”); (b) with respect to data transfers from the United Kingdom, Module 1 (controller to controller) of the EU SCCs as further amended by Part 2: Mandatory Clauses of the Approved Addendum (the “UK Mandatory Clauses”), together with any other necessary conforming changes to the EU SCCs (collectively, the “UK SCCs”); and (c) any updated, revised, or separate clauses relating to data transfer requirements of the GDPR issued from time to time by the European Commission, UK Information Commissioner’s Office, any other applicable data protection authority, or other body with competent authority and jurisdiction.
11. “Shared Personal Data” means Personal Data Processed by a Party to the extent such Party received that Personal Data from the other Party (that other party, the “Sharing Party” under this definition) in connection with the performance of the Agreement. For the avoidance of doubt, a Party is also deemed to “receive” Personal Data from a Sharing Party where the Sharing Party grants access to such Personal Data to the receiving Party.
12. “Transparency Notices” has the meaning given to it in clause 3.2(a).
13. The terms “Controller,” “Process,” “Processor,” “Data Subject,” and “Personal Data,” shall have the meanings given in EU Data Protection Law. To the extent Data Protection Laws use different terms to cover concepts similar to those covered under the aforementioned bold terms in this Section 2.13, then “Controller,” “Process,” “Processor,” “Data Subject,” and “Personal Data” shall have the meaning assigned to those different terms under such Data Protection Laws.
DATA PROCESSING; INDEPENDENT CONTROLLERS
1. AppLovin and User: (a) are independent Controllers with regard to the Shared Personal Data; and (b) will individually determine the purposes and means of its processing of Personal Data.
2. Each Party shall, with respect to the Processing of any Shared Personal Data, comply with Data Protection Laws, including as follows:
  1. each Party shall provide all applicable notices to Data Subjects as required under Data Protection Laws for the lawful Processing by it of Shared Personal Data (“Transparency Notices“). As required under Data Protection Laws, User shall disclose its use of the Services and how AppLovin Processes Personal Data in its Transparency Notices;
  2. each Party shall provide all required mechanisms for, and give effect to, applicable Data Subject Rights pursuant to Data Protection Laws and respond to inquiries by governmental authorities;
  3. User shall not disclose Shared Personal Data with any third parties except as expressly permitted under the Agreement. Further, User shall delete all Shared Personal Data promptly upon the occurrence of any of the following: (i) where User does not place the winning bid for an impression to which that Shared Personal Data relates or (ii) after User provides an Advertisement (directly or indirectly, such as via a third-party ad server in the latter case) in response to an ad request to which that Shared Personal Data relates. Without limiting the foregoing, User shall not, and shall not permit any third party to, use any Shared Personal Data in connection with any profiling or tracking of any end user or any other Data Subject or of any mobile property or publisher;
  4. neither Party shall Process the Shared Personal Data for any purpose other than as set out in its Transparency Notice and unless such Processing is also authorized under Data Protection Laws and the Agreement;
  5. each Party shall ensure that all of its employees engaged in the Processing of such Shared Personal Data act consistently with this DPA;
  6. each Party shall implement technical and organisational security measures to prevent (i) the accidental, unlawful, or unauthorized destruction, loss, alteration, or disclosure of, or access to, Shared Personal Data or (ii) any other security incident that amounts to a “personal data breach” (as such term or similar term, such as “breach of the security system” or “data breach,” is defined under Data Protection Laws) of Shared Personal Data (in either case of (i) and (ii), a “Data Breach”); and
  7. each Party agrees that any agreement with a subprocessor shall comply with the Data Protection Laws.
3. Each Party shall in particular, unless prohibited under applicable law, notify the other without undue delay (i) of any requests to exercise Data Subject Rights received by that Party regarding the Shared Personal Data, to the extent such notices are required under Data Protection Law; (ii) about regulatory inquiries involving the Processing of Shared Personal Data, and (iii) any Data Breach involving the Shared Personal Data to the extent resulting in material destruction, loss, alteration, or disclosure of, or access to, that Shared Personal Data.
4. Without limitation of the obligations and restrictions otherwise set forth in this DPA and elsewhere in the Agreement, each Party shall provide all required notices to, and obtain all necessary permissions and consents from, the relevant Data Subjects whenever required under the Data Protection Laws to lawfully permit such Party’s Processing of Shared Personal Data in its capacity as an independent Controller of the Shared Personal Data.
5. User shall honor, in compliance with Applicable Data Protection Laws and applicable self-regulatory frameworks, all signals that AppLovin sends to User regarding whether the Data Subject has provided, or has not provided (or has withdrawn), consent or opted out of “sales” or “shares” (as such terms “sale” and “share” are defined under the Data Protection Laws and CCPA, respectively) or any similar signals (e.g., an opt out of targeted advertising).
6. With respect to the CCPA, (i) without limitation of any other restrictions set forth in the Agreement, the Shared Personal Data is disclosed to User for the limited and specified purposes of enabling User to bid on advertising inventory or serve Advertisements through the Services and User shall Process the Shared Personal Data only for such purposes; (ii) User shall comply with the CCPA, including by providing the same level of privacy protection as required of Businesses under the CCPA; (iii) AppLovin may take reasonable and appropriate steps to ensure that User Processes Shared Personal Data in a manner consistent with AppLovin’s obligations under the CCPA; (iv) User shall notify AppLovin promptly after User makes a determination that it can no longer meet its obligations under the CCPA; and (v) AppLovin may, upon notice, take reasonable and appropriate steps to stop and remediate the unauthorized Processing of Shared Personal information.
7. If User qualifies as a “foreign party” as defined in 28 CFR Part 202 (or similar laws in applicable jurisdictions), User represents and warrants that it will not sell, provide access to, or otherwise share or attempt to share any data provided to User pursuant to its use of the Services to “countries of concern” or “covered persons” as defined in 28 CFR Part 202. If User knows or suspects that a country of concern or covered person has gained access to any data provided to User pursuant to its use of the Services, User represents and warrants that it will immediately notify AppLovin and take other appropriate steps required under applicable laws.
GENERAL
1. In the event of any conflict or discrepancy between the SCCs, the Agreement, and this DPA, the following order of precedence will apply: (i) the SCCs, (ii) this DPA, and (iii) the Agreement.
2. This DPA does not alter the limitations of liability set out in the Agreement.
3. This DPA will become effective on the date User has accepted the Agreement or the date on which the User started to use the Services. This DPA will terminate simultaneously and automatically upon the termination or expiration of the Agreement.
4. To the extent required by Data Protection Law, this DPA will be governed by the laws of the applicable jurisdiction. In all other cases, this DPA shall be governed by the laws of the jurisdiction set forth in the Agreement.
INTERNATIONAL TRANSFERS
1. The Parties agree that the SCCs shall apply to the transfer of, including access to, Shared Personal Data in the case of a transfer from AppLovin to User, where:
  1. the User is not established in an Adequate Jurisdiction; and
  2. the Processing of the Shared Personal Data is subject to EU Data Protection Law or the LGPD or AppLovin is otherwise contractually required to enter into the SCCs.
2. For the purposes of the SCCs:
  1. Annex 1.A (List of Parties) shall be deemed to incorporate the information in Schedule I;
  2. Annex 1.B (Description of Transfer) shall be deemed to incorporate the information in Schedule III;
  3. Annex 1.C (Competent Supervisory Authority) shall be deemed to refer to the supervisory authority identified in Schedule II;
  4. Annex II (Technical and Organisational Measures) shall be deemed to incorporate the information in Schedule II;
  5. The optional language within clause 7 of the SCCs does not apply;
  6. The optional language within clause 11(a) of the SCCs does not apply;
  7. Pursuant to clause 17, the SCCs will be governed by the laws of Germany;
  8. Pursuant to clause 18(b) of the SCCs, the Parties shall resolve disputes under the SCCs before the courts of Germany;
  9. In relation to Table 4 referenced in the UK Mandatory Clauses, neither Party will be entitled to terminate the Approved Addendum in accordance with clause 19 of the UK Mandatory Clauses; and
  10. For data exporters established within Brazil (for purposes of transfers of Shared Personal Data under the LGPD), the SCCs shall be governed by the laws of the Federative Republic of Brazil. Further, for such transfers under the LGPD, the applicable Data Protection Law shall be understood as the LGPD and the supervisory authority is the National Data Protection Authority in Brazil (ANPD).

SCHEDULE I

PARTIES

Contractual party and Role	Address of the party, contact person’s name, position and contact details and, where applicable, of its data protection officer and/or representative in the EU	Activities relevant to the data transferred under these Clauses
AppLovin (Controller)	AppLovin Corporation Address: 1100 Page Mill Road, Palo Alto, CA 94304 USA E-mail: [email protected]	Personal Data is transferred from AppLovin to the User in connection with the Services.
User (Controller)	As specified in the Agreement.	Personal Data that is made available to User in connection with the Services.

SCHEDULE II

SCCS

Information deemed incorporated into the SCCs
Data exporter	AppLovin
Data importer	User
Annex I.A	List of Parties: Relevant information regarding “Data exporter” and “Data importer” under this Schedule I and Schedule II are incorporated by reference herein.
Annex I.B	Description of Transfer: Relevant information from Schedule III below is incorporated by reference herein.
Annex I.C	Competent Supervisory Authority: The competent supervisory authority shall be the Landesbeauftragte für den Datenschutz Niedersachsen (the State Commissioner for Data Protection of Lower Saxony), except that, in the case of the UK SCCs, the competent supervisory authority under the UK SCCs will be the UK Information Commissioner.
Annex II	Technical and Organisational Measures: Data importer will implement and maintain appropriate administrative, physical, and technical safeguards for the protection of the security, confidentiality, and integrity of Shared Personal Data, including: 1. Measures for pseudonymization and encryption of Shared Personal Data: A. Data minimization and privacy-by-design into its software or other product/service development lifecycle to prevent Shared Personal Data from being used in a manner inconsistent with the Agreement. For example, Data importer only works with pseudonymized data and has international controls to prohibit internal personnel and any relevant subprocessors from re-identifying data to any directly identifying Personal Data (e.g., name, address). B. User does not utilize sensitive Personal Data (e.g., “special categories of Personal Data” under the GDPR) or directly identifiable Personal Data in connection with its use of the Services. C. User utilizes appropriate, industry standard cryptography when storing Shared Personal Data (e.g., encryption at rest) and when utilizing hashed or other cryptographically protected identifiers, wherever feasible. 2. Measures for ensuring ongoing confidentiality of processing systems and services: A. User has implemented and maintains a written information security program and has implemented measures to ensure the integrity, availability, and security of Personal Data, including regular vulnerability scans and endpoint protection. B. User has a documented data retention/deletion schedule that aligns with the retention/deletion requirements under the Agreement with respect to Shared Personal Data. 3. Measures for ensuring ongoing integrity of processing systems and services: A. User has implemented and maintains a written information security program that contains administrative, technical, and physical safeguards appropriate to protect against potential Data Breaches and remediate actual or reasonably suspected Data Breaches, and that meet (i) industry best practices in relation to User’s industry and (ii) any security requirements required under Data Protection Laws. 4. Measures for ensuring ongoing availability and resilience of processing systems and services: A. User maintains Shared Personal Data availability and resilience via its written information security program, such as via secured and monitored operational sites, event and other auditable logs, tolerant infrastructure with appropriate redundancies, processes and policies for incident response and vendor due diligence, business continuity plans, backup procedures, and disaster recovery plans. 5. Measures for ensuring the ability to restore the availability and access to Shared Personal Data in a timely manner in the event of a physical or technical event: A. See above. 6. Processes for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures in order to ensure the security of the Processing: A. At least annually, security measures and the written information security program are reviewed and tested for alignment with the requirements herein and industry best practices. B. Security compliance is integrated within User’s product/service development lifecycle and User’s teams collaborate regularly to ensure those standards are kept up to date. 7. Measures for user identification and authorization: A. User has procedures in place to authenticate and respond to requests from Data Subjects who have submitted rights requests (e.g., access, portability, erasure), and such procedures comply with Data Protection Laws. B. User has operational and technical controls in place to ensure appropriate system access control with respect to Shared Personal Data and related infrastructure, such that only authorized personnel are granted access based on a “need to know” (and that unauthorized current or former personnel cannot improperly access such systems). 8. Measures for the protection of Shared Personal Data during storage: A. See above, and the Agreement more broadly, for limitations on how User can Process the Shared Personal Data. B. User has implemented and maintains data minimization procedures with respect to Shared Personal Data stored on User’s, or its subprocessors, systems. 9. Measures for ensuring physical security of locations at which Shared Personal Data is Processed: A. Facilities involved in the Processing of Shared Personal Data are accessible only be authorized personnel and there are logical and physical controls in relation thereto (e.g., two-factor authentication, firewalls, anti-malware, access controls, VPNs, access badges and logs, physical barriers). 10. Measures for ensuring accountability A. User has performed a data mapping exercise that is compliant with Data Protection Laws and has created an appropriate record of Processing activities in relation thereto. B. User has implemented a privacy program appropriate to the scope and nature of the Personal Data Processed, including, as applicable, reviewing and complying with self-regulatory frameworks where appropriate, conducting data protection impact assessments, and appointing a data protection officer (DPO) or other individuals responsible for privacy and data security as appropriate.

SCHEDULE III

DESCRIPTION OF THE TRANSFER

Categories of data subjects whose data is transferred

The personal data transferred concern the following categories of data subjects:

Individuals who are the subject of a bid request sent from AppLovin to User or otherwise are served an impression.

Categories of data transferred

The personal data transferred concern the following categories of data:

Mobile device advertising identifiers (e.g., IDFA/Google Ad ID, IP address) or other digital/device identifiers

Device/user agent data such as make, model, operating system, device properties and settings, location data, application ID, and application version

Click and view (impression) data

Sensitive data transferred (if applicable)

The personal data transferred concern the following categories of sensitive data:

None.

The frequency of the transfer

The transfer will take place on a real-time, continuous basis pursuant to the Agreement

Nature of the processing and purpose of the transfer(s) and further processing

The Personal Data is Processed in connection with the use of the Services in accordance with the Agreement.

The period for which the personal data will be retained, or, if that is not possible, the criteria used to determine that period

User will not retain the Shared Personal Data for longer than as permitted under the Agreement.

For transfers to (sub-)processors, also specify subject matter, nature and duration of the processing

The Personal Data transferred may be disclosed only to the following recipients or categories of recipients:

Service providers that User uses in connection with the Services and those otherwise described in its Transparency Notice.

The duration of Processing will align with the data retention period described above.

AppLovin Legal Information

Content

Effective Date: July 3, 2025

SCOPE
1. The Parties agree to enter into this DPA for the purposes of ensuring compliance with applicable Data Protection Laws. User enters into this DPA on behalf of itself and on behalf of its authorized Affiliates. AppLovin may receive Personal Data through User’s use of the Services and, in consideration of the mutual obligations set out herein, the Parties agree to comply with the following provisions with respect to any Personal Data Processed through the Services. Except as modified below, the terms of the Agreement shall remain in full force and effect.
DEFINITIONSIn addition to the terms defined in the Agreement and above, the following terms shall have the following meanings for the purposes of this DPA:
1. “Adequate Jurisdiction” means a country which ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data, as determined by the European Commission in the case that GDPR applies, and as determined by the UK Information Commissioner’s Office in the case that the UK GDPR applies.
2. “Affiliates” means an entity that directly or indirectly controls, is controlled by, or is under common control with, a Party.
3. “Approved Addendum” means the template addendum (version B.1.0) issued by the United Kingdom International Commissioner’s Office (ICO) and laid before the United Kingdom Parliament in accordance with s119A of the Data Protection Act 2018 on 2 February 2022, as it is revised under Section 18 of such addendum.
4. “CCPA” means the California Consumer Privacy Act of 2018, Cal Civ. Code §1798.100 et seq., and all implementing regulations, as amended from time to time, such as by the California Privacy Rights Act of 2020 (“CPRA”).
5. “Data Protection Laws” means EU Data Protection Law, the CCPA, the Brazilian General Personal Data Protection Law, No. 13,709/2018 (the “LGPD”), and any other legislation protecting natural persons’ right to privacy with regard to the processing of Personal Data to the extent applicable to a Party’s Processing of Personal Data under the Services.
6. “Data Subject Rights” means the rights granted to Data Subjects under Data Protection Laws.
7. “EU Data Protection Law” means the GDPR, the e-Privacy Directive and national implementing legislation and the Swiss Federal Data Protection Act.
8. “GDPR” means the EU General Data Protection Regulation 2016/679 of the European Parliament and of the Council (“EU GDPR”) and, where applicable, the “UK GDPR” as defined in the Data Protection, Privacy and Electronic Communications (Amendment Etc.) (EU Exit) Regulations 2019.
9. “Member State” means a member state of the European Economic Area, together with Switzerland and the United Kingdom.
10. “SCCs” means (a) with respect to data transfers from the European Union to third countries that are not deemed adequate jurisdiction by the European Commission, Module 1 (controller to controller) of the Standard Contractual Clauses annexed to Commission Implementing Decision (EU) 2021/914 (the “EU SCCs”); (b) with respect to data transfers from the United Kingdom, Module 1 (controller to controller) of the EU SCCs as further amended by Part 2: Mandatory Clauses of the Approved Addendum (the “UK Mandatory Clauses”), together with any other necessary conforming changes to the EU SCCs (collectively, the “UK SCCs”); and (c) any updated, revised, or separate clauses relating to data transfer requirements of the GDPR issued from time to time by the European Commission, UK Information Commissioner’s Office, any other applicable data protection authority, or other body with competent authority and jurisdiction.
11. “Shared Personal Data” means Personal Data Processed by a Party to the extent such Party received that Personal Data from the other Party (that other party, the “Sharing Party” under this definition) in connection with the performance of the Agreement. For the avoidance of doubt, a Party is also deemed to “receive” Personal Data from a Sharing Party where the Sharing Party grants access to such Personal Data to the receiving Party.
12. “Transparency Notices” has the meaning given to it in clause 3.2.1.
13. The terms “Controller,” “Process,” “Processor,” “Data Subject,” and “Personal Data,” shall have the meanings given in Data Protection Laws. To the extent Data Protection Laws use different terms to cover concepts similar to those covered under the aforementioned bold terms in this Section 2.13, then “Controller,” “Process,” “Processor,” “Data Subject,” and “Personal Data” shall have the meaning assigned to those different terms under such Data Protection Laws.
DATA PROCESSING; INDEPENDENT CONTROLLERS
1. AppLovin and User: (a) are independent Controllers with regard to the Shared Personal Data; and (b) will individually determine the purposes and means of its Processing of Personal Data.
2. Each Party shall, with respect to the Processing of any Shared Personal Data, comply with Data Protection Laws, including as follows:
  1. each Party shall provide all applicable notices, disclosures, and privacy policy to Data Subjects as required under Data Protection Laws for the lawful Processing by it of Shared Personal Data (“Transparency Notices“). User shall disclose its use of the Services, its sharing or otherwise making available of Personal Data with/to AppLovin, and how AppLovin Processes Personal Data in its Transparency Notices. For example, for Users that have embedded AppLovin advertising Services in their mobile applications or websites, this can be done by including the following language in the User’s Transparency Notices: “We work with AppLovin to deliver ads. For more information about AppLovin’s collection and use of your information, visit: /”;
  2. each Party shall provide all required mechanisms for, and give effect to, applicable Data Subject Rights pursuant to Data Protection Laws and respond to inquiries by governmental authorities;
  3. neither Party shall Process the Shared Personal Data for any purpose other than as set out in its Transparency Notice and unless such Processing is also authorized under Data Protection Laws and the Agreement;
  4. each Party shall ensure that all of its employees engaged in the Processing of such Shared Personal Data act consistently with this DPA;
  5. each Party shall implement technical and organisational security measures to prevent (i) the accidental, unlawful, or unauthorized destruction, loss, alteration, or disclosure of, or access to, Shared Personal Data or (ii) any other security incident that amounts to a “personal data breach” (as such term or similar term, such as “breach of the security system” or “data breach,” is defined under Data Protection Laws) of Shared Personal Data (in either case of (i) and (ii), a “Data Breach”); and
  6. each Party agrees that any agreement with a subprocessor shall comply with the Data Protection Laws.
3. Each Party shall in particular, unless prohibited under applicable law, notify the other without undue delay (i) of any requests to exercise Data Subject Rights received by that Party regarding the Shared Personal Data, to the extent such notices are required under Data Protection Law; (ii) about regulatory inquiries involving the Processing of Shared Personal Data, and (iii) any Data Breach involving the Shared Personal Data to the extent resulting in material destruction, loss, alteration, or disclosure of, or access to, that Shared Personal Data.
4. User represents and warrants it has provided (and shall maintain) all required notices in compliance with Section 3.2.1 and obtained all necessary permissions and consents required under the Data Protection Laws from the relevant Data Subjects on behalf of AppLovin to lawfully permit AppLovin to Process Personal Data as contemplated in the Agreement and Applicable Data Protection Laws.
5. Where consent is the lawful basis for Processing Personal Data or otherwise required for the use of the Services, User represents and warrants that it shall, at all times, make available, maintain, and make operational on the User’s properties: (i) a mechanism for obtaining such consent from Data Subjects in accordance with the requirements of the Data Protection Laws; and (ii) a mechanism for Data Subjects to withdraw such consent (opt-out) in accordance with the Data Protection Laws.
6. With respect to the CCPA, (i) the Shared Personal Data is disclosed to AppLovin for the limited and specified purposes of enabling AppLovin (or its demand partners) to bid on advertising inventory, serve Advertisements in connection with the Services, and optimize the Services, as further set forth in AppLovin’s Transparency Notices; (ii) AppLovin shall comply with the CCPA, including by providing the same level of privacy protection as required of Businesses under the CCPA; (iii) User may take reasonable and appropriate steps to ensure that AppLovin Processes Shared Personal Data in a manner consistent with User’s obligations under the CCPA; (iv) AppLovin shall notify User promptly after AppLovin makes a determination that it can no longer meet its obligations under the CCPA; and (v) User may, upon notice, take reasonable and appropriate steps to stop and remediate the unauthorized Processing of Shared Personal Data.
7. If User qualifies as a “foreign party” as defined in 28 CFR Part 202 (or similar laws in applicable jurisdictions), User represents and warrants that it will not sell, provide access to, or otherwise share or attempt to share any data provided to User pursuant to its use of the Services to “countries of concern” or “covered persons” as defined in 28 CFR Part 202. If User knows or suspects that a country of concern or covered person has gained access to any data provided to User pursuant to its use of the Services, the User represents and warrants that it will immediately notify AppLovin and take other appropriate steps required under applicable laws.
GENERAL
1. In the event of any conflict or discrepancy between the SCCs, the Agreement, and this DPA, the following order of precedence will apply: (i) the SCCs, (ii) this DPA, and (iii) the Agreement.
2. This DPA does not alter the limitations of liability set out in the Agreement.
3. This DPA will become effective on the date User has accepted the Agreement or the date on which the User started to use the Services. This DPA will terminate simultaneously and automatically upon the termination or expiration of the Agreement.
4. To the extent required by Data Protection Law, this DPA will be governed by the laws of the applicable jurisdiction. In all other cases, this DPA shall be governed by the laws of the jurisdiction set forth in the Agreement.
INTERNATIONAL TRANSFERS
1. The Parties agree that the SCCs shall apply to the transfer of, including access to, Shared Personal Data:
  1. in the case of a transfer from User to AppLovin, where the Processing of the Shared Personal Data by the User is subject to EU Data Protection Law or the LGPD; or
  2. in the case of a transfer from AppLovin to User, where:
    - the User is not established in an Adequate Jurisdiction;
    - the Processing of the Shared Personal Data is subject to EU Data Protection Law or the LGPD or AppLovin is otherwise contractually required to enter into the SCCs.
2. For the purposes of the SCCs:
  1. Annex 1.A (List of Parties) shall be deemed to incorporate the information in Schedule I;
  2. Annex 1.B (Description of Transfer) shall be deemed to incorporate the information in Schedule III;
  3. Annex 1.C (Competent Supervisory Authority) shall be deemed to refer to the supervisory authority identified in Schedule II;
  4. Annex II (Technical and Organisational Measures) shall be deemed to incorporate the information in Schedule II;
  5. The optional language within clause 7 of the SCCs does not apply;
  6. The optional language within clause 11(a) of the SCCs does not apply;
  7. Pursuant to clause 17, the SCCs will be governed by the laws of Germany;
  8. Pursuant to clause 18(b) of the SCCs, the Parties shall resolve disputes under the SCCs before the courts of Germany;
  9. In relation to Table 4 referenced in the UK Mandatory Clauses, neither Party will be entitled to terminate the Approved Addendum in accordance with clause 19 of the UK Mandatory Clauses; and
  10. For data exporters established within Brazil (for purposes of transfers of Shared Personal Data under the LGPD), the SCCs shall be governed by the laws of the Federative Republic of Brazil. Further, for such transfers under the LGPD, the applicable Data Protection Law shall be understood as the LGPD and the supervisory authority is the National Data Protection Authority in Brazil (ANPD).

SCHEDULE I

PARTIES

Contractual party and Role	Address of the party, contact person’s name, position and contact details and, where applicable, of its data protection officer and/or representative in the EU	Activities relevant to the data transferred under these Clauses
AppLovin (Controller)	AppLovin CorporationAddress: 1100 Page Mill Road, Palo Alto, CA 94304 USAE-mail: [email protected]	Personal Data is transferred to AppLovin from the User in the course of providing the Services.
User (Controller)	As specified in the Agreement.	Personal Data that is made available to AppLovin in connection with the use of the Services by the User.

SCHEDULE II

SCCS

Information deemed incorporated into the SCCs
Data exporter	User is the data exporter to the extent User provides and Processes Personal Data of EU and UK Data Subjects in connection with the use of the Services. AppLovin is the data exporter to the extent AppLovin transfers Personal Data of EU and UK Data Subjects to User in connection with the Services.
Data importer	AppLovin is the data importer to the extent User qualifies as data exporter according to what is set out above. User is the data importer to the extent AppLovin is the data exporter according to what is set out above.
Annex I.A	List of Parties: Relevant information regarding “Data exporter” and “Data importer” under this Schedule I and Schedule II are incorporated by reference herein.
Annex I.B	Description of Transfer: Relevant information from Schedule III below is incorporated by reference herein.
Annex I.C	Competent Supervisory Authority: The competent supervisory authority shall be determined based on the situation applicable to the data exporter under clause 13 of the Model Clauses (e.g., if the data exporter is established in an EU member state, or falls under GDPR Article 3(2) and has an appointed representative under GDPR Article 27(1), or falls under GDPR Article 3(2) and has not appointed a representative under GDPR Article 27(1)), except that, in the case of the UK SCCs, the competent supervisory authority under the UK SCCs will be the UK Information Commissioner.
Annex II	Technical and Organisational Measures: Data importer will implement and maintain appropriate administrative, physical, and technical safeguards for the protection of the security, confidentiality and integrity of Personal Data uploaded to the Services. Where AppLovin acts as the data importer, those measures shall be set forth in an AppLovin security statement. Data importer will make that statement available to data exporter upon request.

SCHEDULE III

DESCRIPTION OF THE TRANSFER

Categories of data subjects whose data is transferred

The personal data transferred concern the following categories of data subjects:

Individuals who are end-users of User’s digital property (including mobile application(s), websites, and connected TV devices, and e-commerce platforms) (each, an “End User”).
Individuals who are User’s marketing and business contacts.
Individuals whose navigation of a digital property such as a mobile application or website has triggered an advertising bid request.
Individuals who are User’s employees, agents, or representatives in AppLovin’s online platform.

Categories of data transferred

The personal data transferred concern the following categories of data:

Mobile device advertising identifiers (e.g., IDFA/Google Ad ID, IP address);
Device data such as make, model, operating system, device properties and settings, coarse location data;
Click attribution data and transactional data;
Business contact and billing information (e.g., name, email address, billing address, telephone number, VAT number, bank account number to the extent considered personal data); and
(For end-users of User’s e-commerce platform or merchant website and individuals who interact with e-commerce ads):
- Shopping and browsing data and events such as shopping browsing behavior (e.g., views) and search history, records of products purchased or considered (e.g., added to cart, check out), purchasing histories, tendencies or preferences; and information regarding user interactions with advertising partners and their merchant partners’ sites and advertisements.

Sensitive data transferred (if applicable)

The personal data transferred concern the following categories of sensitive data:

None.

The frequency of the transfer

In the case that AppLovin and the User agree to Services embedded on a digital property such as live mobile application(s), the transfer will take place in real time every time an end–user accesses and navigates the digital property(-ies).

Nature of the Processing and Purpose of the transfer(s) and further Processing

The Personal Data is Processed for the purpose of providing the Services in accordance with the Agreement, including all permissible purposes set forth in the respective data importer’s Transparency Notice.

The period for which the personal data will be retained, or, if that is not possible, the criteria used to determine that period

AppLovin retains an End User’s Personal Data collected through the Services until AppLovin stops receiving updated information from the End User’s device for a continuous period of two (2) years, or until the End User requests deletion – whichever occurs first.

For transfers to (sub-)processors, also specify subject matter, nature and duration of the Processing

The Personal Data transferred may be disclosed only to the following recipients or categories of recipients:

Service providers that AppLovin uses to provide the Services and those described in its Transparency Notice.
Service providers that User uses to implement, operate, and optimize the Services and those described in its Transparency Notice.

The duration of Processing will align with the data retention period described above.

AppLovin Legal Information

Content

Effective Date: June 30, 2025

Introduction

Collection, Use, and Disclosure of Personal Information

Category of Personal Information Collected	Source(s) of Personal Information	Business Purpose(s) for Collection	Disclosure for a Business Purpose
Identifiers, such as IP address and Advertising IDs (IDFA/GAID/Amazon FOSAID) if available.	• You or your device(s) • Publishers • Advertising Partners • Affiliates	• Service Delivery • Delivery of Advertisements • Technical Support • Customer Support • Processing Payments • Analytics • Business Research & Development • Marketing & Promotions • Platform Protection & Fraud Prevention • Compliance with Legal Obligations	• Service Providers • Affiliates • Advertising Partners • Your Specified Recipient(s) • Government Entities/Law Enforcement
Additional Customer Records, such as bank account number or other financial information	• You (only for business users)	• Service Delivery • Technical Support • Customer Support • Processing Payments • Platform Protection • Compliance with Legal Obligations	• Service Providers • Your Specified Recipient(s)
Characteristics of Protected Classifications, such as age or gender	N/A	N/A	N/A
Sensitive Personal Information, such as social security numbers, precise geolocation, or genetic and biometric data*	N/A	N/A	N/A
Commercial Information, such as records of services considered or other purchasing or consuming histories or tendencies	• You or your device(s) • Publishers	• Service Delivery • Delivery of Advertisements • Analytics • Business Research & Development • Platform Protection & Fraud Prevention • Compliance with Legal Obligations	• Service Providers • Your Specified Recipient(s)
Internet or Network Information, such as information regarding interactions with a website, application, or advertisement, or online shopping browser history	• You or your device(s) • Service Providers • Publishers	• Service Delivery • Delivery of Advertisements • Analytics • Business Research & Development • Platform Protection & Fraud Prevention • Compliance with Legal Obligations	• Service Providers • Affiliates • Advertising Partners • Your Specified Recipient(s)
Geolocation Data, such as city or 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) • Publishers • Advertising Partners • Affiliates • Service Providers	• Service Delivery • Delivery of Advertisements • Analytics • Business Research & Development • Platform Protection & Fraud Prevention • Compliance with Legal Obligations	• Service Providers

When you use a mobile application, the publisher of that application may decide to serve you with interest-based ads. If that application embeds AppLovin’s software, we’ll send a bid request that contains certain of your device information (if available) to our advertising demand side partners to enable their ads to be served to you based on your interests (which they derive independently or from other third-party advertising partners). Under the CCPA and other State Privacy Laws, passing device data in a bid request to our demand side partners is “sharing” (under the CCPA) and may be a “sale” of personal information.

Data Retention

Your Privacy Rights

Privacy Right	Brief Details
Know and Access your Personal Information/Portability	Under the State Privacy Laws, you have the right to obtain confirmation regarding whether we are processing your personal information and to access that personal information and, in some cases, information about the third parties who may receive such personal information. You also have the right to access that personal information in a portable, readily usable format, unless not technically feasible to provide in such a format. With respect to the CCPA’s right to access, you have the right to request the following: (a) the specific pieces of personal information the business has collected about you and (b) the categories of personal information collected, the sources of collection, the business/commercial purpose for collecting or “selling/sharing” personal information, and the categories of third parties to whom the business discloses personal information.
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 or Targeted Advertising	AppLovin may disclose or otherwise process 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.” In certain circumstances, you have the right to opt-out of “sales” or “sharing” of your personal information (i.e., Identifiers and Internet/Network Information to Advertising Partners) for purposes of serving you with targeted ads or content, otherwise referred herein as “cross-contextual behavioral advertising” or “targeted advertising.”
Non-Discrimination	You have the right to exercise the rights conferred on you by the State Privacy Laws without discrimination.
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.
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 Profiling in Furtherance of Decisions that Produce Legal or Similarly Significant Effects	In certain circumstances, you have the right to opt-out of the use of your personal information for profiling in furtherance of decisions that produce legal or similarly significant effects.

How to Exercise Your Privacy Rights

For Users of Mobile Games and/or Other Applications, Platforms, or Services Containing the AppLovin SDK or Similar Technologies

To access or delete the personal information that AppLovin may have about you from the mobile games or other applications, platforms, or services that you use (e.g., personal information used as part of our Advertising Services), you may download the AppLovin Privacy Management Application from the Apple or Google Play Stores:

To exercise your right to opt-out of “sales/shares” or “targeted advertising” with respect to AppLovin’s Advertising Services, you have the following options:

Opt-Out through AppLovin Ads. AppLovin allows you to opt-out of all interest-based advertising served by AppLovin through the “i” or “Learn more about ad preferences” link available on the face of an ad served by AppLovin. Once you click on the link, you will see a button to “Opt-Out of Interest-Based Advertising.”

Opt-Out through Device-Level Choices. In addition, if you do not want to receive interest-based advertisements, you can limit the collection of certain information through your device’s settings. Detailed instructions on how to change these device settings can be found in the “Manage Your Privacy Choices” section of our Privacy Policy and in the instructions available here.

Please know that opting out of targeted advertising does not mean that you will not receive advertising. You may still receive ads, but those ads may be less relevant to your interests.

For Our Website Visitors

To control data collection and sharing via certain cookies or other data collection technologies on our website, you can click “Cookie Settings” in the footer of our website. In addition, you may follow the steps outlined in the “Cookies and Other Similar Technology” section of our Privacy Policy. To access or delete information that you have manually submitted to us, please contact our Data Protection Officer using the information in the “Contact Us” section of our Privacy Policy.

For Our Customers and Business Contacts

Please contact our Data Protection Officer using the information in the “Contact Us” section of our Privacy Policy. Please provide enough information about you and your request for our Data Protection Officer to be able to identify your information in our records.

* * * *

Children Under the Age of 16

Appointment of an Authorized Agent

Data Access and Deletion Transparency Report

Our annual transparency report shows the number of data access and deletion requests we received last year and how long it typically takes us to fulfill those requests.

Type of Request	Requests Completed*	Average Time to Substantively Respond
Requests to Know and Access	1250	Less than 1 day (successful requests processed automatically)
Requests for Deletions	7392	Less than 1 day (successful requests processed automatically)

Updates or Amendments to this Notice

How to Contact Us

You can find our contact information in the “Contact Us” section of our Privacy Policy.

AppLovin Legal Information

Content

These Terms of Use (the “Agreement”) govern the relationship between you (“User,” “you” or “your”) and These Terms of Use (the “Agreement”) govern the relationship between you (“User,” “you” or “your”) and AppLovin Corporation, a Delaware corporation, or AppLovin (Singapore) Pte. Ltd., a Singapore company, if applicable (collectively, “AppLovin,” “we” or “our,” and together with “User,” the “Parties,” and each a “Party”) and apply to your use of the Services (as defined below). For purposes of this Agreement, and depending upon how you use the Services, you have contracted with the following AppLovin entity:

Advertisers in the United States — If your principal place of business is in the United States of America or its territories, you have entered into this Agreement with AppLovin Corporation.
Advertisers in all Non-U.S. Regions — If your principal place of business is outside of the United States of America or its territories, you have entered into this Agreement with AppLovin (Singapore) Pte. Ltd., except for the Data Processing Agreement incorporated into this Agreement, which you have entered into with AppLovin Corporation as the parent corporation for AppLovin (Singapore) Pte. Ltd.
Publishers in Singapore — If your principal place of business is in Singapore, you have entered into this Agreement with AppLovin (Singapore) Pte. Ltd., except for the Data Processing Agreement incorporated into this Agreement, which you have entered into with AppLovin Corporation as the parent corporation for AppLovin (Singapore) Pte. Ltd.
Publishers worldwide, excluding Singapore — If your principal place of business is in any other country or region except Singapore, you have entered into this Agreement with AppLovin Corporation.

Please read this Agreement and our Privacy Policy carefully before using the Services. By accessing the AppLovin platform, currently located at www.applovin.com and on other pages (the “Platform”), or registering, enabling, or using any of the Services (as defined in Section 1 below), you become a User and agree to be bound by this Agreement. If you do not agree to this Agreement, you must not use (or you must stop using) the Platform or the Services. Your access to and use of the Platform or the Services may also be subject to additional terms or agreements between us and you.

If you have entered into this Agreement on behalf of a company or other entity, you represent that you have been duly authorized with the authority to enter into this Agreement on behalf of that company or other entity, and you expressly represent that the company or other entity agrees to be bound by this Agreement. In that case, the term “you” refers to the third party or parties on a joint and several basis. If you have entered into this Agreement on an individual basis, you represent that you are the age of legal majority or older in your jurisdiction (aged 18 and over) and have the legal capacity to enter into and be bound by this Agreement.

As described below, the Platform, the Services, and the Software may fall within United States export controls. You may not use the Platform or the Services if United States law or other applicable law preclude you from receiving products, including services or the Software, from the United States or from using the Platform, the Services, or the Software. Registration for and use of the Platform or the Services where prohibited will be void.

SECTION 14 OF THIS AGREEMENT CONTAINS AN INFORMAL DISPUTE RESOLUTION PROCESS, A BINDING AGREEMENT TO ARBITRATION, AND A CONSOLIDATED, CLASS ACTION, AND REPRESENTATIVE ACTION WAIVER, AND SECTION 9 CONTAINS WARRANTY DISCLAIMERS AND A LIMITATION OF OUR LIABILITY. BY USING THE PLATFORM OR THE SERVICES, YOU AGREE TO THESE PROVISIONS.

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1. The Services; Changes to the Services or this Agreement

AppLovin operates a suite of tools for developers and other businesses to automate and optimize the marketing and monetization of their platforms, products, or services by enabling the placement of different types of advertisements on digital properties (including mobile apps, websites, and connected TV devices) and distributing our customers’ mobile apps, platforms, products, or services to end users using various technologies, including AI-powered tools and the Software (collectively, the “Services”). AppLovin may offer additional services or revise any of the Services, at its discretion, and this Agreement will apply to all additional services or revised Services. As explained below, AppLovin also reserves the right to stop offering any of the Services and to immediately suspend or terminate your access to any of the Services.

Registration and Account Information — You need to register and create an account to access the Platform and the Services (or some portion of them) for your own (i.e., individual or entity) use only. By registering and creating an account to access the Platform and the Services (or some portion of them), you agreed to be bound to this Agreement. You must provide us with accurate, complete, and up-to-date account information. In addition, you may not authorize others to use your account, and you may not assign or otherwise transfer your account or this Agreement to any other person or entity. You also understand that you must keep your account information secure and that you should not disclose your account credentials to anyone. You alone remain solely responsible for all activities that occur under your account, regardless of whether you know about them or not.

Updates or Changes to the Platform or the Services—We may from time-to-time update, improve, enhance, conduct testing, and further develop the Platform or the Services (for example, in the form of bug fixes, enhancements, security patches, new software modules, or new versions). You understand that these improvements, enhancements, or tests may impact your or end users’ experience. In addition, we may add or remove functionalities or features of the Platform or the Services at any time, and we may modify, suspend, restrict, terminate, or stop the Platform or the Services (or any portion of them) at any time. We may also suspend, restrict, delete, or remove access to the Platform or the Services (or any portion of them) or your account at any time.

Notifications and Messages from the Platform or the Services — We may from time-to-time send you notifications or messages regarding the Platform, the Services, and the Software. By using the Services, you consent to receive these messages from us, our affiliates, or providers.

Changes to this Agreement—We may modify or update this Agreement (including the Publisher Policies, Demand Policies, EULA, Privacy Policy, Platform DPA, and Demand Partner DPA incorporated into and made a part of this Agreement). If we modify or update this Agreement, we will post the revised Agreement, which will generally become effective 30 days later. In addition, we may notify you directly via email and/or through the Platform or the Services. By continuing to use the Platform, the Services, or the Software after those modifications or updates become effective, you agree to be bound by the revised Agreement. If you do not agree to be bound by the revised Agreement, then you must not use the Platform, the Services, and the Software anymore.

Retention — By creating a business account, you agree that your account and related data will be retained for the required periods under applicable law.

2. Your Use of the Platform and the Services

Advertisers’ Use of the Platform and the Services — Advertisers, media buyers, ad agencies, demand-side platforms, e-Commerce platforms, channel partners, or merchants, or other providers of advertisements (collectively, “Advertisers” or an “Advertiser”) may provide content, including text links, banners, videos, artwork, and graphics (“Advertisements”), and AppLovin may collect content, including text links, videos, artwork, and other files, for display on any Property.

If you use the Services as an Advertiser or as any other entity that bids on advertising inventory or serves Advertisements through the Services, you must comply with the AppLovin Policies for Demand Partners (the “Demand Policies”) and shall not contribute, submit, or make available through the Services, or use the Services in connection with, any Advertisements or content that violate the Demand Policies.

In addition, you hereby grant AppLovin a perpetual, irrevocable, sublicensable, non-exclusive, worldwide, and royalty-free right and license to copy, adapt, reproduce, distribute, display, publicly perform, and otherwise use Advertisements and other content, including any intellectual property rights contained on these materials, for the purpose of providing the Services, including serving the Advertisements and distributing Advertisers’ platforms, products, or services to end users. In addition, you grant AppLovin a perpetual, irrevocable, sublicensable, non-exclusive, worldwide, and royalty-free right and license to use and retain data collected from you for purposes of improving the Services, including our AI-powered technologies and Software.

Publishers’ Use of the Platform and the Services — Developers and other businesses (collectively, “Publishers” or a “Publisher”) may list digital properties, including mobile applications, websites, connected TV devices, and other platforms or services (each a “Property,” and collectively “Properties”), and make them available for Advertisements (as defined above).

If you use the Services as a Publisher, you must comply with the AppLovin Policies for Publishers (the “Publisher Policies”) and shall not contribute, submit, or make available through the Services, or use the Services in connection with, any Property or content that violates the Publisher Policies. As set forth below and in the Publisher Policies, Publishers may not generate or engage in, or authorize or encourage any third party to generate or engage in, invalid activity, invalid traffic, fraudulent impressions of, or fraudulent clicks on, any Advertisement (as defined above) through any means. AppLovin will determine what constitutes valid impressions, clicks, requests, valid traffic, and valid activity, and payments to you as a Publisher may be withheld or adjusted if you engage in any actual or suspected violation of this Agreement or the Publisher Policies.

In addition, you hereby grant AppLovin all the necessary rights and permissions to: (a) use your Property’s or Properties’ intellectual property rights provided during the Services for the purpose of fulfilling AppLovin’s obligations; (b) access, index, store, and cache requests made from Property or Properties to the Services, including by automated means; and (c) access your Property or Properties to provide the Services, including placing or displaying Advertisements. In addition, you grant AppLovin a perpetual, irrevocable, sublicensable, non-exclusive, worldwide, and royalty-free right and license to use and retain data collected from you for purposes of improving the Platform and the Services, including our AI-powered technologies and Software.

Eligibility to Use the Platform and the Services — You agree to use the Platform and the Services consistent with this Agreement and all laws and regulations, including United States export controls, 28 CFR Part 202, and similar requirements. In addition, you may not use the Platform, the Services, or the Software if you or any of your affiliates or, to your knowledge, any director, officer, manager, or employee of such entities: (i) cannot receive products, including services or the Software, from the United States (because for example you live in a country embargoed by the United States) or have been the target of sanctions by any governmental entity; (ii) cannot access or use the Platform, the Services, or the Software in compliance with this Agreement under the applicable laws of your jurisdiction; (iii) have previously been suspended from the Services; or (iv) qualify as (1) a foreign entity headquartered in or organized under the laws of a “country of concern” as defined in 28 CFR Part 202; (2) a foreign entity 50% or more owned by a country of concern or covered person as defined in 28 CFR Part 202; (3) a foreign individual primarily resident in a country of concern as defined in 28 CFR Part 202; or (4) a foreign individual who serves as an employee or contractor of a covered person entity or a country-of-concern government as defined in 28 CFR Part 202.

Your Access to and Use of Our Software — You may have access to software development kits (SDKs), applications programming interfaces (APIs), pixels, other integrations, documentation, tools and assemblies, libraries, scripts, object code, sample source code, and similar developer material made available by AppLovin specifically for purposes of your access to and use of the Platform and the Services (the “Software”). This Agreement and the End User License Agreement (the “EULA”) govern your use of the Software owned by AppLovin and provided to you only for purposes of your access to and use of the Platform and the Services.

Third-Party SDKs or Other Software Integrations — Your use of any third-party SDKs, APIs, pixels, connections, or similar software in connection with the Services will be governed by the terms of any agreement applicable to those integrations, connections, or software. We have no responsibility for any aspect of these third-party integrations, connections, or software, including any ad serving or data processing that may occur through them. You and the third-party provider must ensure compliance with all applicable laws and regulations, including those concerning privacy and data protection, age-related restrictions, labeling and disclaimer requirements, advertising guidelines, and any similar requirements.

3. Our Retained Proprietary Rights; Restrictions on Your Use

Except for the limited license granted herein, we and our licensors retain all legal right, title, and interest in and to the Platform and the Services, including all of the intellectual property associated with the Platform and the Services, the technologies and the Software used to provide the Platform or the Services, the advertisements created by AppLovin except to the extent they include your intellectual property (the “AppLovin Ads”), any improvements or derivative products or services, and all other aspects of the Platform and the Services. We reserve all rights not expressly granted to you.

Restrictions on Your Access and Use — You agree not to access or use the Platform or the Services (or any part of them) other than as permitted by this Agreement. You agree not to modify, create derivative works based on, decompile, reverse engineer or disassemble, or otherwise attempt to extract source code from, the Platform or the Services (or any part of them). In addition, you may not (a) copy, distribute, rent, lease, lend, sublicense, transfer or make the Platform or the Services available to any third party; (b) attempt to defeat, avoid, by-pass, remove, deactivate or otherwise circumvent any software protection mechanisms in the Platform or the Services; (c) modify, remove, or obscure any proprietary notices or legends that appear on the Platform or the Services or during the use and operation thereof; (d) sell, assign, license, disclose, or otherwise transfer or make available the Platform or the Services, any copies of the Platform or the Services, or any information derived from the Platform or the Services in any form to any third parties; or (e) remove or alter any proprietary notices or marks on the Platform or the Services.

This Agreement does not grant you or any other party any right, title, or interest in the Platform or the Services, any content in the Platform or the Services (including any AppLovin Ads), or in our or our licensors’ trademarks, logos, and other intellectual property. We reserve all rights not expressly granted to you.

Our Use of Your Feedback — If you make suggestions regarding any features, functionality, or performance of the Platform, the Services, or the Software that AppLovin adopts for any of its products or services, such features, functionality, and performance shall be deemed automatically assigned to AppLovin under this Agreement and become our sole and exclusive property.

4. Data Privacy and Data Sharing

Data Processing Agreement — To the extent that any Personal Data (as defined under applicable data protection laws) is shared hereunder, the processing of such Personal Data shall be governed by the terms set forth in the Platform Data Processing Agreement (the “Platform DPA”) for AppDiscovery Advertisers, e-Commerce, Advertisers, and MAX Publishers; and Demand Partner Data Processing Agreement (the “Demand Partner DPA”) for ALX Demand Side Partners, respectively, which are incorporated into and made a part of this Agreement. As described above, you have entered into the Platform DPA or Demand Partner DPA, as applicable, with AppLovin Corporation.

Data Sharing Representations and Warranties — You represent and warrant, as applicable, that:

You will comply with all applicable laws, rules, and regulations relating to the collection, use, and sharing of information about any end user who interacts with the Services.
You will ensure that you will have, at all times, a clearly labeled and easily accessible privacy policy that complies with all applicable laws and specifically provides end users with clear information about SDKs, cookies, device-specific information, location information, and other information stored on, accessed on, or collected from end users’ devices in connection with the Services.
You will ensure (where required by law) that each end user consents to the storing and accessing of cookies, device-specific information, or other information on the end user’s device by AppLovin in connection with the Services, and upon AppLovin’s request, provide us with written evidence of such consent, including the date of the consent and the consent language presented to the end user.
You will ensure that you have adequate rights and have obtained all necessary permissions and consents required under applicable laws to disclose Personal Data to AppLovin for purposes consistent with this Agreement, including improving the Services.
You shall, at all times and in accordance with the requirements of applicable data protection laws, make available, maintain, and make operational on your properties: (i) a mechanism for obtaining such consent from end users; and (ii) a mechanism to honor end users’ data subject rights (opt-out of sale for interest-based advertising, deletion, access, etc.).

Complying with 28 CFR Part 202 and Similar Requirements — If you qualify as a “foreign party” as defined in 28 CFR Part 202, you may not sell, provide access to, or otherwise share or attempt to share any data provided to you pursuant to your use of the Services to “countries of concern” or “covered persons” as defined in 28 CFR Part 202. If you know or suspect that a country of concern or covered person has gained access to any data provided to you pursuant to your use of the Services, you must immediately notify us and take other appropriate steps required under applicable laws. Failure to comply with this requirement will constitute a breach of this Agreement and may constitute a violation of 28 CFR Part 202.

AppLovin Privacy Policy — Our Privacy Policy describes how we collect, use, disclose, share, and otherwise process information and material provided by you. By accessing and using the Platform or the Services, you affirm that you have reviewed and acknowledge the terms of the Privacy Policy.

5. Prohibition on Children Data and Using the Services for Children or Apps Exclusively Targeted to Children

Whether you are a Publisher or Advertiser, you may not provide AppLovin with children data or cause that information to be provided via a third party. You may not initialize or use any AppLovin SDK in any way or otherwise use any aspect of the Services in connection with an end user who qualifies as a “child” under applicable laws. Please note that jurisdictions define the term “child” differently and these definitions may change over time. You shall be solely responsible for (1) determining whether an end user of your Property or Advertisement qualifies as a “child” under applicable laws and (2) taking the steps necessary to ensure that you do not initialize or use any AppLovin SDK in any way or otherwise use any aspect of the Services in connection with a “child” under applicable laws.

In addition, you acknowledge and agree that you will not use the Services in connection with any Property or Advertisement exclusively designed for or exclusively directed to children as defined and required by applicable laws, or for any Property or Advertisement that could implicate the Children’s Online Privacy Protection Act of 1998 (15 U.S.C. 6501, et seq.) (“COPPA”), laws of similar effect in any applicable jurisdiction, as well as any applicable app store policies. You shall be solely responsible for ensuring that any Property or Advertisements comply with all age-related laws and applicable app store policies, including COPPA or laws of similar effect in any applicable jurisdiction.

As explained above, in the Privacy Policy, the Publisher Policies, and the Demand Policies, children may not use the Services, you may not initialize or use any AppLovin SDK in any way or otherwise use any aspect of the Services in connection with a child, and AppLovin does not knowingly collect personal information from children or serve advertisements to children.

If you believe we served an advertisement to a child or might have personal information from or about a child, or if you believe a User may be exclusively designed for or exclusively directed to children, or may be knowingly passing personal information from children to us, please contact us via email at [email protected].

6. Fees and Payments

a. Fees from Advertisers’ Use of the Services

Payments from Advertisers — For purposes of your use of the Services, AppLovin will provide you with access to an online system to manage and analyze your Advertisements served through the Services, maintain and update your payment and billing information, and perform other functions related to your account and Advertisements. AppLovin manages Advertisers’ spend through Daily Spend Limits and Monthly Invoicing as applicable.

Daily Spend Limits — If you are an e-Commerce Advertiser, you will by default be subject to daily spend limits and required to pay-as-you-go for your use of the Services and any applicable Taxes (as defined below) via AppLovin’s online system. AppLovin will charge your designed payment method each day up to your daily spend limit or deduct that amount against your available account balance. As such, you must maintain a positive account balance or designate an accepted payment method for automatic charges in AppLovin’s online system to serve Advertisements through the Services. If your account balance falls to zero or your designated payment method fails to process, AppLovin will discontinue serving your Advertisements through the Services. To restart the delivery of your Advertisements, you must deposit sufficient funds via AppLovin’s online system to establish a positive account balance or designate an accepted payment method for automatic charges. Advertisers subject to daily spend limits acknowledge and understand that AppLovin will charge their designated payment methods or deduct against their available account balances for Advertisements served through the Services (and any applicable Taxes as defined below) exclusively based on the numbers in AppLovin’s online system. In addition, all amounts must be paid in U.S. Dollars regardless of your primary place of business.
Monthly Invoicing — All Advertisers except for e-Commerce Advertisers will pay for their use of the Services after invoicing by AppLovin. Advertisers acknowledge and understand that AppLovin will invoice them for Advertisements served through the Services (and any applicable Taxes as defined below) exclusively based on the numbers in AppLovin’s online system. Unless otherwise indicated, payment will be due within thirty (30) days of the invoice date, and all amounts will be payable in U.S. Dollars regardless of your primary place of business.

Advertisers acknowledge and agree that they must comply with all payment and billing information in AppLovin’s online system or otherwise provided by AppLovin and pay all applicable Taxes as defined below. AppLovin reserves the right, in its sole discretion, to modify the payment or billing requirements, change the supported payment methods via AppLovin’s online system (or any aspect of them, including requiring payments over certain amounts to be submitted via specific payment methods), modify daily spending limits or credit limits as applicable, or implement other account, payment, or billing changes at any time.

Past Due Accounts — If your payment method fails or any account(s) becomes past due, AppLovin may take steps to collect past due amounts using any available mechanisms, including netting or offsetting any past due amounts from payments to you as a Publisher or due to you under any other agreement, suspending or terminating your account(s), referring the balance to collections, or pursuing the balance through other available means. You agree to pay all expenses associated with any such mechanism, including reasonable attorneys’ fees, court costs, or collections’ fees, plus interest accruing on any past due amounts at the lesser of 1% per month or the lawful maximum.

b. Payments to Publishers

Payments to Publishers — For purposes of your use of the Services, AppLovin will provide you with access to an online system to manage and analyze your Advertisements served through the Services, maintain and update your payment and billing information, and perform other functions related to your account. You acknowledge and understand that AppLovin will pay you monthly earnings for valid impressions filled by AppLovin, calculated exclusively based on AppLovin’s accounting and the numbers in AppLovin’s online system, and subject to the minimum applicable payment threshold (communicated through the Services). Payments to you will be calculated by AppLovin based on valid impressions served on your Property by AppLovin and the pricing associated with those impressions, which could take the form of cost per mille (CPM) or a percentage of Net Revenue (as defined below) as determined by AppLovin.

Invalid Activity — For purposes of calculating these payments, AppLovin will, in its sole discretion, determine what constitutes valid impressions, clicks, requests, valid traffic, and valid activity. Invalid activity includes: (i) spam, invalid impressions, or invalid clicks on Advertisements generated by any person, bot, automated program, or similar device, including through any clicks or impressions originating from your IP addresses, computers under your control, or similar self-click schemes; (ii) clicks solicited or impressions generated by payment of money and false representation; (iii) clicks or impressions co-mingled with a significant amount of the activity described in (i) and (ii) above; or (iv) any breach of this Agreement or the Publisher Policies. As described in this Agreement and the Publisher Policies, AppLovin will only pay you for valid impressions served on your Property by AppLovin.
Net Revenue — For purposes of calculating these payments, “Net Revenue” means revenues actually received by AppLovin from the sale, use, or other disposition of Advertisements displayed on your Property, less Taxes (as defined below), less any agency commissions, buyer fees, carrier and/or partner fees, and less any allowances actually made or taken for returns, cash discounts, or promotional allowances, but excluding other revenues indirectly earned, if applicable, for consulting, planning and targeting, copywriting, site building, account management, or technical modifications or technical innovations that may be charged by AppLovin to third parties from time to time. The portion of Net Revenue received by User will generally be determined on the first Monday of each calendar month, on which day those revenues accrued to your account thirty (30) or more days earlier shall become eligible to be paid.

Subject to the foregoing and the minimum applicable payment threshold, AppLovin will pay your monthly earnings according to the payment details entered into your AppLovin account. You acknowledge and affirm that you are the beneficial owner of the bank account(s) reflected in your payment details. Depending upon those payment details, you may be responsible for certain bank fees associated with the transmission of payments from your AppLovin account. As set forth above, to help ensure proper payment, you remain solely responsible for providing and maintaining accurate contact and payment information associated with your account.

Our Right to Withhold, Adjust, or Offset Payments — We may withhold, adjust, or offset payments to you based upon any amounts you owe to AppLovin under this Agreement or any other agreement, any amounts refunded or credited to Advertisers, any amounts arising from invalid activity, or if you engage in any actual or suspected violation of this Agreement or the Publisher Policies, in any case as determined by AppLovin in its sole discretion.

Payments from Other Networks — Your monthly earnings for impressions filled through the Services by other networks, as may be reflected in AppLovin’s online system, will be paid in accordance with the policies and practices of those other networks.

c. Miscellaneous Provisions

Taxes — You will pay (or have your account charged or deducted for) any direct or indirect local, state, federal or foreign taxes, levies (including any equalization levy), duties, or similar governmental assessments of any nature, including but not limited to VAT, GST, excise, sales, use, consumption, and withholding taxes (collectively, “Taxes”) or other charges in connection with its use of the Platform, the Services, or the Software, including any Taxes AppLovin is legally obligated to charge. AppLovin’s fees do not include Taxes and you agree to pay, in addition to such fees, all applicable Taxes imposed by any taxing authority in connection with your use of the Services. In all cases, you shall pay the full amount owed to AppLovin, inclusive of and without deduction for, any invoiced Taxes. Advertisers subject to daily spend limits acknowledge and understand that AppLovin will charge their designated payment methods or deduct against their available account balances to cover any applicable Taxes. You may provide AppLovin with an exemption certificate or equivalent information acceptable to the relevant taxing authority, in which case AppLovin will not charge or collect the Taxes covered by such certificate. Where a Publisher supplies a Property or Properties to AppLovin which is subject to any Taxes, Publisher shall be responsible for remitting the Taxes to the proper authorities. Where applicable, Publisher agrees to GST self-billing for Singapore GST purposes and agrees to remit all GST output tax to the proper authorities, as required by law, as shown on each AppLovin self-billed invoice. Upon request, Publisher shall provide AppLovin with its GST registration number.

Payment Processing Fees — You will pay any processing fees associated with your payment of invoices from AppLovin. In all cases, you shall pay the full amount owed to AppLovin, inclusive of and without deduction for, any processing fees associated with your payment.

Changes to Fees or Charges — AppLovin reserves the right to change its fees and to institute new charges at any time, upon prior notice, and to invoice for fees and/or make payments for earnings from any of our affiliates.

Refund of Unused Account Balance — If this Agreement terminates or your account remains inactive for more than ninety (90) continuous days, then AppLovin will upon request and as soon as reasonably practicable refund your available account balance less any fees owed by you to AppLovin or applicable Taxes.

7. Confidentiality Obligations

AppLovin Confidential Information — “AppLovin Confidential Information” includes: (a) all Software, technology, and documentation relating to the Platform and the Services and any other non-public technical or business information; (b) the existence of, and information about, beta features in the Services (or any aspect of them); (c) the terms of any order with AppLovin, pricing information related to the Services, and any statistics provided by AppLovin concerning your use of the Platform and the Services; and (d) any other information made available to you by AppLovin that either has been marked as confidential or would ordinarily be considered confidential given the nature of the information or the relevant circumstances. AppLovin Confidential Information does not include information (i) that you already knew prior to your use of the Services or the Platform, (ii) that becomes public through no fault of yours or breach by you of this Agreement, (iii) that you independently developed without use of AppLovin Confidential Information, or (iv) that you rightfully obtained from a third party without restriction on use or disclosure.
Use and Disclosure Restrictions — You agree not to use AppLovin Confidential Information except as permitted under this Agreement or any other agreement, terms, or policies that govern your access and use of the Platform and the Services. You further agree not to disclose AppLovin Confidential Information without our prior written consent. In addition, without our prior written consent, you will not post, copy, modify, transmit, disclose, show in public, create any derivative works from, distribute, make commercial use of, or reproduce any (i) AppLovin Confidential Information or (ii) copyrighted material, trademarks, or other proprietary information accessible through the Platform or the Services. These restrictions do not prevent you from disclosing AppLovin Confidential Information: (a) pursuant to a court order or other lawful process, provided that you first give AppLovin sufficient advanced notice of such disclosure pursuant to any such order or other lawful process; and (b) on an as-needed confidential basis to your legal or financial advisors.

8. Report Advertisements, Properties, or Content; Trademark & DMCA Policy

Report Properties, Advertisements, or Content — If someone may have violated this Agreement, misused the Platform or the Services, used the Services for inappropriate or unlawful Properties, Advertisements, or content, or engaged in other inappropriate or unlawful activity, or if you have any other issue you would like to raise with us, please visit AppLovin Support or submit your questions and requests to the AppLovin Support Team.

Trademark & DMCA/Copyright Policy — We respect the intellectual property rights of others and ask that you do the same. We respond to notices of alleged trademark or copyright infringement, consistent with the US Digital Millennium Copyright Act or laws of similar effect. For more information, please review our Copyright Page. We reserve the right, in our sole discretion and without notice, to terminate your access to the Platform and the Services if we determine that you may be a “repeat infringer.”

9. Warranty Disclaimers and Limitation of Our Liability

Some jurisdictions do not allow the exclusion of certain warranties or the limitation of certain liabilities. In those jurisdictions, the exclusions and limitations below shall apply only to the extent permitted by the laws of these jurisdictions.

Warranty Disclaimers — You access and use the Platform, the Services, and the Software at your own sole risk. We provide the Platform, the Services, and the Software on an “as is” and “as available” basis, and explicitly disclaim all warranties of any kind to the full extent permitted by applicable law.

We make no representations or warranties of any kind, express or implied, as to the operation of the Platform, the Services, or the Software, the Advertisements, Properties, or content included on or otherwise made available through the Services, or any other information, content, materials, or other services included on or otherwise made available through the Platform and the Services. In addition, we may suspend, withdraw, or restrict the availability of all or any part of the Platform, the Services, or the Software (including “beta” features or tools) at any time and for any reason.
You expressly agree that you use the Platform, the Services, and the Software at your sole risk. To the full extent permissible by law, we disclaim all warranties, express or implied, about the Platform, the Services, and the Software, including implied warranties of merchantability, fitness for a particular purpose, quiet enjoyment, non-infringement or availability, and any warranties arising out of course of dealing or usage of trade. No advice or information, whether oral or written, obtained from us or elsewhere will create any warranty or condition not expressly stated in this Agreement.
We do not warrant that the Platform, the Services, or the Software will meet your requirements or be available on an uninterrupted, secure, or error-free basis (meaning free of viruses or other harmful components), that defects will be corrected, or that you will not encounter any connectivity problems or other technical issues.
We make no warranty regarding the quality, accuracy, or appropriateness of any Advertisement, Property, or content included on or otherwise made available through the Platform or the Services. You acknowledge and agree that AppLovin has no control over (or responsibility for) any content that may be submitted or published by any advertiser (including Advertisements) or any content that may be available or published on any Property (or otherwise).
YOU ACCESS AND USE THE PLATFORM, THE SERVICES, AND THE SOFTWARE AT YOUR SOLE RISK. WE EXPLICITLY DISCLAIM ANY WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED, ABOUT THE PLATFORM, THE SERVICES, AND THE SOFTWARE.

Limitation of Our Liability and Cap on Damages — To the full extent permissible by law, you acknowledge and agree that neither we nor any other party involved in creating or delivering the Platform, the Services, or the Software (including our affiliates, corporate parents, advertisers, and distribution partners), will be liable:

For any personal injury or indirect, incidental, punitive, special, exemplary, consequential, liquidated, or punitive damages, including lost profits, loss of data or goodwill, service interruption, computer damage, system failure, or the cost of substitute services, in anyway whatsoever (and under any theory in any applicable jurisdiction, including warranty, contract, and tort or negligence) arising out of or in connection with this Agreement or your use of, access to, or inability to use or access the Platform, the Services, or the Software even if we have been advised of the possibility of such damages; or
For the conduct of any third parties, including other users of the Platform, the Services, or the Software, or operators of external platforms, websites, or resources, and end users.

THE RISK OF USING THE PLATFORM, THE SERVICES, AND THE SOFTWARE RESTS ENTIRELY WITH YOU, AS DOES THE RISK OF ANY FORM OF INJURY FROM THE SERVICES OR THE CONDUCT OF THIRD PARTIES.

In addition, to the full extent permissible by law, the aggregate (or total) liability of us (and any other party involved in creating, producing, or delivering the Platform, the Services, or the Software, including our affiliates and corporate parents) to you arising out of or relating to this Agreement, your relationship with us, or your use of or access to the Platform, the Services, and the Software will not exceed the lesser of (a) ten thousand U.S. dollars (US$10,000) or (b) the total amount paid or payable to you or payable by you in the three (3) month period immediately before you first assert any claim. These limitations and exclusions regarding damages apply even if any remedy fails to provide adequate compensation. Notwithstanding anything in the foregoing, if no amount has been paid or become payable to you or payable by you in the three (3) month period immediately before you first assert any claim, our aggregate (total) liability in any form of action whatsoever in connection with this Agreement, your relationship with us, or your use of or access to the Platform, the Services, and the Software will be the total sum of twenty U.S. dollars (US$20). In the event that you assert any claim seeking statutory damages or penalties, you agree to waive any right to stack or combine those statutory damages or penalties in calculating the damages sought by you.

10. Your Indemnification of Us

You will indemnify and hold AppLovin, its officers, managers, directors, employees, affiliates, and subsidiaries, and each of their respective legal representatives, successors, and assigns, harmless (and, at AppLovin’s request, defend AppLovin) against any and all claims, demands, losses, costs, liabilities, and expenses (including reasonable attorneys’ fees) relating to or arising out of (a) your use of the Platform or the Services, (b) your violation of any term of this Agreement, including your representations and warranties, (c) your violation of any third-party rights, or (d) your violation of any applicable laws, rules, or regulations, including those concerning privacy and data protection.

At AppLovin’s option, you will assume control of the defense, but AppLovin retains the right to elect to take over the defense at any time. You may not enter into a settlement covered by this indemnification clause without AppLovin’s prior written consent. If AppLovin elects to assume control of the defense, you agree to cooperate fully in that defense.

11. Ending Your Relationship with the Services (and vice versa)

Termination by Us — We may suspend or terminate this Agreement, your account(s), or your access to and use of the Platform, the Services, and the Software (or any portion of them) at any time, for any reason or no reason, and without notice or explanation to you. In addition, we reserve the right to remove your account information or data from the Platform, the Services, the Software, and any other records at any time, for any reason or no reason, and without notice or explanation to you.

Termination by You — You may terminate this Agreement at any time by following the instructions on the Platform or in other documentation, or by sending a notice of cancellation to AppLovin Support.

Survival and Effect of Termination — Upon suspension or termination of this Agreement, your account(s), or your access to and use of the Platform, the Services, and the Software (or any portion of them), your right to use the Platform, the Services, and the Software will immediately cease and you must promptly remove all Software and pay any amounts owed to AppLovin pursuant to the applicable invoices. In addition, all provisions of this Agreement which by their nature should survive will survive, including, without limitation, confidentiality provisions, fees and payments, indemnification, warranty disclaimers, limitations of our liability, and dispute resolution provisions.

12. Your Representations and Warranties to AppLovin

Representations and Warranties by Publishers — If you access and use the Platform, the Services, or the Software as a Publisher, you represent and warrant that: (i) you own each Property that you use in connection with the Services or that you have the legal authority and authorization to act on behalf of the owner of such Property for purposes of this Agreement; (ii) you have all necessary rights, power, and authority to enter into this Agreement and to perform the acts required hereunder; (iii) any data supplied or disclosed to AppLovin under or in connection with the Platform, the Services, or the Software shall be controlled, collected, and transferred in accordance with any applicable data protection laws and regulations; (iv) any data supplied or disclosed to AppLovin includes all necessary rights, licenses, consents, and permissions for AppLovin to receive, use, share, and transfer such data as set forth in this Agreement; and (v) you and each of your Properties will comply with the Publisher Policies.

In addition, you represent and warrant that each of your Properties and any material displayed on those Properties: (a) comply with all applicable laws, statutes, ordinances, and regulations, including consumer protection, commerce, advertising, and product laws; (b) do not breach and have not breached any third-party rights, including intellectual property rights, rights of publicity or privacy, or rights, duties, or obligations under consumer protection, commerce, product liability, advertising, tort, or contract theories; and (c) comply with the Publisher Policies.

Representations and Warranties by Advertisers — If you access and use the Platform, the Services, or the Software as an Advertiser, you represent and warrant that: (i) you own each Advertisement you designate in connection with the Services or that you have the legal authority and authorization to act on behalf of the owner of such Advertisement for the purposes of this Agreement; (ii) you have all necessary rights, power, and authority to enter into this Agreement and to perform the acts required hereunder; (iii) any data supplied or disclosed to AppLovin under or in connection with the Platform, the Services, or the Software shall be controlled, collected, and transferred in accordance with any applicable data protection laws and regulations; (iv) any data supplied or disclosed to AppLovin includes all necessary rights, licenses, consents, and permissions for AppLovin to receive, use, share, and transfer such data as set forth in this Agreement; and (v) you and each of your Advertisements will comply with the Demand Policies.

In addition, you represent and warrant that each of your Advertisements and any material displayed therein: (a) comply with all applicable laws, statutes, ordinances, and regulation, including consumer protection, commerce, advertising, and product laws; (b) do not breach and have not breached any third-party rights, including intellectual property rights, rights of publicity or privacy, or rights, duties, or obligations under consumer protection, commerce, product liability, advertising, tort, or contract theories; (c) do not include viruses and any other form of contaminants of any nature; and (d) comply with the Demand Policies.

Compliance with Anti-Bribery and Anti-Corruption Laws — Publishers and Advertisers represent and warrant that they will comply with all applicable anti-bribery and anti-corruption laws, including the U.S. Foreign Corrupt Practices Act of 1977 (as amended), the U.K. Bribery Act 2010, and laws of similar effect in any applicable jurisdiction. You will maintain adequate internal controls and procedures and take other steps to ensure compliance with all applicable anti-bribery and anti-corruption laws and agree to provide reasonable support to us in the event of any investigation related to your compliance.

13. Governing Law and Venue for Legal Disputes Not Subject to Arbitration

This Agreement, and all claims or defenses based on, arising out of, or related to this Agreement or the relationship of the Parties under this Agreement, including those arising from or related to the negotiation, execution, performance, or breach of this Agreement, shall be governed by, and enforced in accordance with, the internal laws of the State of California, without reference to its choice of law rules or any principle calling for application of the law of any other jurisdiction.

Except as provided below, any disputes not subject to the Agreement to Arbitration set forth in this Agreement shall be heard only in the state or federal courts located in Santa Clara County, California, unless we mutually agree to some other location. Each of us consents to venue and personal jurisdiction in Santa Clara County, California, for purposes of any such action.

14. Informal Dispute Resolution Process; Agreement to Arbitration; Consolidated, Class Action, and Representative Action Waiver

Notice of Dispute and Required Informal Dispute Resolution Process

Except as provided below, if any dispute arises between us concerning or relating to this Agreement, the Platform, the Services, the Software, or our relationship, we agree to work in good faith to resolve the dispute informally by providing a written notice of dispute (the “Notice of Dispute”) to the applicable Party. Any Notices of Dispute should be submitted to AppLovin’s Support Team.

Agreement to Arbitration; Exceptions to Agreement to Arbitration

As set forth in the table below, the specific details of this Agreement to Arbitration, including the Governing Law, the Alternative Dispute Resolution Provider, the Applicable Rules, and the Designated Venue for any arbitral proceedings, each as defined in the tables below, depend upon your principal place of business and whether you are a Publisher or Advertiser.

If the Parties cannot informally resolve the dispute within sixty (60) days from receipt of the Notice of Dispute, the Parties agree to submit the dispute arising between them, including any claim or controversy arising out of or relating to this Agreement or the breach, termination, enforcement, interpretation, or validity thereof, including the determination of the scope, applicability, or enforceability of this Agreement to Arbitration, for determination through binding arbitration administered by the Alternative Dispute Resolution Provider pursuant to the Applicable Rules (each as defined in the tables below).

The Parties agree that all arbitration proceedings, including witness interviews, written statements or other submissions, hearings, and the arbitration decision, shall be conducted or rendered in English. At the beginning of any arbitration process under this Agreement, the Parties will select an arbitrator, fluent in English, by mutual agreement. Such an arbitrator shall be a retired judge or justice or another qualified and impartial person that the Parties decide upon, and any such arbitrator shall be subject to disqualification on the same grounds as would apply to a judge or justice in a court proceeding. If the Parties cannot agree on the selection of an arbitrator, the Parties will request a list of an odd number of potential arbitrators from the Alternative Dispute Resolution Provider and alternatively strike potential arbitrators, with AppLovin going first, until one potential arbitrator remains. The Parties agree that the arbitrator shall administer and conduct any arbitration in accordance with California law, including the California Code of Civil Procedure, and that the arbitrator shall apply substantive and procedural California law to any dispute or claim, without reference to rules or principles of conflicts of law. To the extent that the Applicable Rules conflict with California law, California law shall take precedence. The Parties agree that any arbitration under this Agreement shall be conducted exclusively in the Designated Venue. The Parties agree that the decision of the arbitrator shall be rendered within twelve (12) months of the commencement of the arbitration (unless extended by the arbitrator for good cause), and that the decision shall be in a reasoned written opinion based solely upon the law governing the claims and defenses pleaded. The arbitrator’s decision regarding the claims shall be final and binding upon the Parties and shall be enforceable in any court having appropriate jurisdiction within the Designated Venue. The Parties will split equally the arbitrator’s fees and other costs imposed by the Alternative Dispute Resolution Provider, but each Party shall be responsible for paying such Party’s own attorneys’ fees and costs related to the arbitration.   

Exceptions to Agreement to Arbitration

This Section does not apply to the following types of claims or disputes, which you or we may bring in court in accordance with this Agreement:

Your payment obligations under this Agreement or our right to offset or pursue past due accounts through collections or other means;
Claims of infringement or other misuse of intellectual property rights;
Claims for violation of any applicable confidentiality provisions;
Claims for preliminary injunctive relief for any violations of this Agreement;
Claims to request enforcement or recognition of any award or order in any appropriate jurisdiction; and
Our right to suspend or terminate access to the Platform, the Services, or the Software.

For Publishers whose principal place of business is in a country or territory other than Singapore, Advertisers whose principal place of business is in the United States or its territories, and individual Users of the Platform, the specific details of this Agreement to Arbitration are as follows:

Advertisers’ or Publishers’ Principal Place of Business	AppLovin Contracting Entity	Governing Law	Alternative Dispute Resolution Provider & Applicable Rules	Designated Venue
Advertisers: United States or its territories Publishers: Worldwide, except Singapore Individual Users of the Platform: Worldwide	AppLovin Corporation	California, as set forth above, without reference to its choice of law rules or any principle calling for application of the law of any other jurisdiction.	JAMS, administered by JAMS pursuant to (i) the Comprehensive Arbitration Rules & Procedures and (ii) the Mass Arbitration Procedures and Guidelines if seventy five or more demands for arbitration are filed that share common factual or legal issues and if counsel for the parties submitting those demands are the same or coordinated, except as modified by this Agreement to Arbitration	Venue for Arbitration: Santa Clara County, California for any arbitration proceedings, unless the parties agree to some other location. In addition, you and AppLovin Corporation agree to submit to the personal jurisdiction of any federal or state court in Santa Clara County, California in order to compel arbitration, to stay proceedings pending arbitration, or to confirm, modify, vacate, or enter judgment on any arbitral award.

For Advertisers whose principal place of business is outside of the United States, the specific details of this Agreement to Arbitration are as follows:

Advertisers’ Principal Place of Business	AppLovin Contracting Entity	Governing Law	Alternative Dispute Resolution Provider & Applicable Rules	Designated Venue
Worldwide in all non-U.S. Regions, including Asia-Pacific countries or territories, those in the EEA, and the UK	AppLovin (Singapore) Pte. Ltd. (except for the Data Processing Agreement incorporated into this Agreement, which you have entered into with AppLovin Corporation, as explained above)	California, as set forth above, without reference to its choice of law rules or any principle calling for application of the law of any other jurisdiction.	International Centre for Dispute Resolution (ICDR), administered by the ICDR pursuant to the International Arbitration Rules (except as modified by this Agreement to Arbitration)	Venue of Arbitration: Singapore or another location as agreed by the Parties for any arbitration proceedings. In addition, you and AppLovin (Singapore) Pte. Ltd. agree to submit to the personal jurisdiction of the courts of Singapore in order to compel arbitration, to stay proceedings pending arbitration, or to confirm, modify, vacate, or enter judgment on any arbitral award.

For Publishers whose principal place of business is in Singapore, the specific details of this Agreement to Arbitration are as follows:

Publishers’ Principal Place of Business	AppLovin Contracting Entity	Governing Law	Alternative Dispute Resolution Provider & Applicable Rules	Designated Venue
Singapore	AppLovin (Singapore) Pte. Ltd. (except for the Data Processing Agreement incorporated into this Agreement, which you have entered into with AppLovin Corporation, as explained above)	California, as set forth above, without reference to its choice of law rules or any principle calling for application of the law of any other jurisdiction.	International Centre for Dispute Resolution (ICDR), administered by the ICDR pursuant to the International Arbitration Rules (except as modified by this Agreement to Arbitration)	Venue of Arbitration: Singapore or another location as agreed by the Parties for any arbitration proceedings. In addition, you and AppLovin (Singapore) Pte. Ltd. agree to submit to the personal jurisdiction of the courts of Singapore in order to compel arbitration, to stay proceedings pending arbitration, or to confirm, modify, vacate, or enter judgment on any arbitral award.

Consolidated, Class Action, and Representative Action Waiver

For disputes arising between us and you, or any other User, you and we agree that we can only bring a claim against each other on an individual basis. EXCEPT AS PROVIDED HEREIN WITH RESPECT TO MATTERS QUALIFYING AS A MASS ARBITRATION, NEITHER YOU NOR WE CAN BRING A CLAIM AS A PLAINTIFF OR CLASS MEMBER IN A CLASS ACTION, CLASS-WIDE ARBITRATION, CONSOLIDATED ACTION, OR REPRESENTATIVE ACTION. EXCEPT AS PROVIDED HEREIN WITH RESPECT TO MATTERS QUALIFYING AS A MASS ARBITRATION, THE ARBITRATOR CANNOT COMBINE MORE THAN ONE PERSON’S CLAIM INTO A SINGLE CASE, AND CANNOT PRESIDE OVER ANY CONSOLIDATED, CLASS, OR REPRESENTATIVE ARBITRATION PROCEEDING, UNLESS WE BOTH AGREE OTHERWISE IN WRITING. NONETHELESS, IF ANY PORTION OF THIS CONSOLIDATED, CLASS ACTION, OR REPRESENTATIVE ACTION WAIVER IS DEEMED UNENFORCEABLE OR INVALID, THE ARBITRATOR SHALL HAVE AUTHORITY TO ISSUE ANY AND ALL REMEDIES AUTHORIZED BY LAW.

YOU UNDERSTAND THAT, ABSENT THIS AGREEMENT TO ARBITRATION, YOU WOULD HAVE HAD A RIGHT TO LITIGATE THROUGH A COURT, TO HAVE A JUDGE OR JURY DECIDE YOUR CASE, AND TO BE PARTY TO A CONSOLIDATED, CLASS, OR REPRESENTATIVE ACTION. HOWEVER, YOU UNDERSTAND AND CHOOSE TO HAVE ANY CLAIMS DECIDED INDIVIDUALLY AND ONLY THROUGH ARBITRATION.

Severability

This Section applies to the full extent permitted by applicable law. If any competent authority deems any portion of this Section illegal or unenforceable, such provision will be severed and the remainder of this Section will be given full force and effect.

In addition, if any competent authority determines that applicable law precludes the arbitration of any claim, cause of action, or requested remedy, then that claim, cause of action, or requested remedy, and only that claim, cause of action, or requested remedy, will be severed from this Agreement to Arbitration and brought in a court of competent jurisdiction. If that occurs, then you and we agree that the severed claims, causes of action, or requested remedies will be stayed until all arbitrable claims, causes of action, and requested remedies have been resolved by the arbitrator.

15. Miscellaneous Provisions

Entire Agreement — This Agreement, the Privacy Policy, the EULA, the Platform DPA, Demand Partner DPA, the Publishers Policies, the Demand Policies, and any insertion order(s) or similar agreement referencing this Agreement comprise the exclusive understanding and entire agreement between you and AppLovin regarding your access to and use of the Platform, the Services, and the Software, and they supersede and replace all prior understandings or agreements between us related to your access to and use of the Platform, the Services, and the Software (including any prior versions of this Agreement).

No Waiver — Our failure to enforce any right or provision of this Agreement will not be considered a waiver of such right or provision. The waiver of any such right or provision will be effective only if in writing and signed by our duly authorized representative. Except as expressly set forth in this Agreement, the exercise by either party of any of its remedies under this Agreement will be without prejudice to its other remedies under this Agreement or otherwise.

Severability — If for any reason a court of competent jurisdiction finds any provision of this Agreement invalid or unenforceable, that provision will be enforced to the maximum extent permissible, and the other provisions of this Agreement will remain in full force and effect.

Construction — For purposes of contract interpretation, the Parties acknowledge that the terms of this Agreement should not be strictly construed against either Party.

Time Limitation on Claims — You agree that any claim you may have arising out of or relating to this Agreement or your relationship with us must be filed within one (1) year after the purported claim arose. Otherwise, your claim will be permanently barred as untimely.

Our Right of Assignment or Delegation — You may not assign or transfer this Agreement, by operation of law or otherwise, without our prior written consent. We may freely assign or transfer this Agreement without restriction. Subject to the foregoing, this Agreement will bind and inure to the benefit of the parties, their successors, and permitted assigns.

Force Majeure — AppLovin will not be in breach of this Agreement nor liable for any failure or delay in performance of any obligations under this Agreement (and, if applicable, the date for performance of the obligations affected will be extended accordingly) as a result of any event outside the reasonable control of AppLovin affecting its ability to perform any of its obligations under this Agreement, including an act of God, fire, flood, lightning, pandemic, compliance with any law or governmental order, rule, regulation or direction (including sanctions), war, revolution, act of terrorism, riot or civil commotion, strikes, locks outs and industrial action, failure of supplies of power, fuel, communication, transport, equipment, raw materials, or other goods or services.

Restricted Content: Financial Services Revision – September 26, 2025

Restricted Content: CBD/Hemp Products Revision – September 26, 2025

Prohibited Content: Misleading & Deceptive Content Revision – September 26, 2025

U.S. Multistate Privacy Notice Revision – September 26, 2025

Collection, Use, and Disclosure of Personal Information

Selling or Sharing of Personal Information

Data Retention

Your Privacy Rights

How to Exercise Your Privacy Rights

Children’s Privacy

Appointment of an Authorized Agent

Data Access and Deletion Transparency Report

Updates or Amendments to this Notice

How to Contact Us

Privacy Policy Revision – September 22, 2025

Our Advertising Services

General Information Collection and Use

Information Sharing

Manage Your Privacy Choices:

Children’s Privacy

Data Security and Retention

Our Website

Cookies and Other Similar Technology

Additional Information Collection for Business Account Owners

How We Use Your Information

Information Sharing

Links to Other Websites

Updating Information

Your Email Marketing Choices

Children

Data Security and Retention

Additional Provisions for EU/UK/Swiss Individuals

Data Privacy Framework

Lawful Basis for Processing

Your Rights

U.S. Multistate Privacy Notice

Policy Changes

Contact Us

Applovin Platform Data Processing Agreement Revision – September 22, 2025

AppLovin Demand Partner Data Processing Agreement Revision – July 3, 2025

Applovin Platform Data Processing Agreement Revision – July 3, 2025

U.S. Multistate Privacy Notice Revision – June 30, 2025

Collection, Use, and Disclosure of Personal Information

Selling or Sharing of Personal Information

Data Retention

Your Privacy Rights

How to Exercise Your Privacy Rights

Children Under the Age of 16

Appointment of an Authorized Agent

Data Access and Deletion Transparency Report

Updates or Amendments to this Notice

How to Contact Us

Terms of Use Agreement Revision – June 20, 2025

1. The Services; Changes to the Services or this Agreement

2. Your Use of the Platform and the Services

3. Our Retained Proprietary Rights; Restrictions on Your Use

4. Data Privacy and Data Sharing

5. Prohibition on Children Data and Using the Services for Children or Apps Exclusively Targeted to Children

6. Fees and Payments

7. Confidentiality Obligations

8. Report Advertisements, Properties, or Content; Trademark & DMCA Policy

9. Warranty Disclaimers and Limitation of Our Liability

10. Your Indemnification of Us

11. Ending Your Relationship with the Services (and vice versa)

12. Your Representations and Warranties to AppLovin

13. Governing Law and Venue for Legal Disputes Not Subject to Arbitration

14. Informal Dispute Resolution Process; Agreement to Arbitration; Consolidated, Class Action, and Representative Action Waiver

15. Miscellaneous Provisions