Product Privacy Policy

Last updated: 23 January 2025

PRODUCT PRIVACY POLICY

With this privacy policy we, Verve Group Europe GmbH, Karl-Liebknecht-Str. 32, 10178 Berlin Germany (hereinafter „VGE“ or “we”) would like to inform you about the processing of personal data when using our mobile advertising optimization technology (“VGE`s Technology”). VGE’s Technology is integrated into mobile apps to provide personalized ad experiences. The providers of the respective apps (“Publishers”) provide you with additional information about the integration of VGE Technology in their apps.  

This privacy policy describes our practices regarding the handling of personal data that we process from the Publishers’ users. Depending on the constellation, we may act as a controller or as a processor on behalf of the Publisher under data protection law. The relevant information about our relationship with the respective Publisher can be found in the Publisher’s privacy policies.

To access the privacy policy governing the processing of data when visiting our Website, please click here.

1. Provider of VGE’s Technology

VGE’s Technology is provided by

Verve Group Europe GmbH
Karl-Liebknecht-Str. 32
10178 Berlin Germany

Where we are a controller of your data, this is also the entity acting as controller. Should you have any questions or suggestions regarding data protection, please do not hesitate to contact us. You are welcome to direct your data protection concerns to our data protection officer by sending an e-mail to [email protected]. Our full contact details are available here.

Our Data Protection Officer:

Fieldfisher Tech Rechtsanwaltsgesellschaft mbH
Amerigo-Vespucci-Platz 1
20457 Hamburg, Germany

2. Personal Data processing in connection with VGE’s Technology

Data we receive.

First of all, we do not know who you (as a user) are. VGE neither processes direct identifiers, such as names, home addresses, e-mail addresses or similar information of users. That said, we only process data provided by the Publishers, including user information about the interaction with apps, which is recorded, stored and evaluated using temporary identifiers, which VGE cannot match to you as a person (so-called pseudonyms). If we are acting as a processor on behalf of the Publisher, the Publishers determine the purposes and means on how we process users’ data. We have established several technical and legal measures to safeguard that the Publisher’s users have given their consent for our processing.

Data we receive from Publishers differ. Provided there is a legal basis for processing, we typically process:

• Device Identifiers such as the ID for Advertising for iOS (IDFA), Google Advertising ID
• Device Characteristics (device model, platform, operating system version, browser details)
• IP addresses
• Authentication-derived identifiers 
• Browsing and interaction data 
• User-provided data
• Non-precise location data
• Privacy choices

2.2 Purposes of data processing and legal bases.

We process the data received from Publishers so that they can market ad space for targeted in-app advertising and targeting campaigns. When serving personalized mobile advertising, this gives advertisers the opportunity to target users who are actually interested in their products, offers and content.

Our processing activities include the following purposes. When we act as a controller, we rely on the following legal bases. If several legal bases are specified, the choice of the relevant legal basis depends on the decision of the respective Publisher. Further information can be found in the privacy policy of the Publisher.:

Purpose of processing	Legal basis
Store and/or access information on a device Device or similar online identifiers together with other information (e.g. screen size, supported technologies etc.) can be stored or read on your device to recognise it each time it connects to an app or to a website, for one or several of the purposes presented here.	User’s consent (Art. 6 (1) (a) GDPR
Use limited data to select advertising Advertising presented to you on the Publisher’s app can be based on limited data, such as the app you are using, your non-precise location, your device type or which content you are (or have been) interacting with (for example, to limit the number of times an ad is presented to you).	User’s consent if chosen by the Publisher (Art. 6 (1) (a) GDPR  Our legitimate interest in being able to offer our publishers a meaningful product (Art. 6 (1) (f) GDPR)
Use limited data to select advertising taking into account their approximate location when permitted by the user’s device Serving ads to the users taking into account their age, gender, keywords or interests when provided by the user in the host mobile app on the user’s device. Race, religion, politics, sex life, or health are unavailable targeting criterions in VGE’s Technology	User’s consent (Art. 6 (1) (a) GDPR
Create profiles for personalised advertising Information about your activity on the Publisher’s app (such as information you submit, content you look at) can be stored and combined with other information about you (for example, information from your previous activity on the Publisher’s service and other websites and apps) or similar users. This is then used to build or improve a profile about you (that might include possible interests and personal aspects). Your profile can be used (also later) to present advertising that appears more relevant based on your possible interests by this and other entities.	User’s consent (Art. 6 (1) (a) GDPR
Use profiles to select personalised advertising Advertising presented to you on the Publisher’s app can be based on your advertising profiles, which can reflect your activity on the Publisher’s service or other websites or apps (like the forms you submit, content you look at), possible interests and personal aspects.	User’s consent (Art. 6 (1) (a) GDPR
Measure advertising performance Information regarding which advertising is presented to you and how you interact with it can be used to determine how well an advert has worked for you or other users and whether the goals of the advertising were reached. For instance, whether you saw an ad, whether you clicked on it, whether it led you to buy a product or visit a website, etc. This is very helpful to understand the relevance of advertising campaigns.	User’s consent if chosen by the Publisher (Art. 6 (1) (a) GDPR  Our legitimate interest in being able to offer our publishers a meaningful product (Art. 6 (1) (f) GDPR)
Develop and improve services Information about your activity on this service, such as your interaction with ads or content, can be very helpful to improve products and services and to build new products and services based on user interactions, the type of audience, etc. This specific purpose does not include the development or improvement of user profiles and identifiers.	Our legitimate interest in improving our product (Art. 6 (1) (f) GDPR)
Ensure security, prevent and detect fraud, and fix errors Your data can be used to monitor for and prevent unusual and possibly fraudulent activity (for example, regarding advertising, ad clicks by bots), and ensure systems and processes work properly and securely. It can also be used to correct any problems you, the publisher or the advertiser may encounter in the delivery of content and ads and in your interaction with them.	Our legitimate interest in being able to offer our Publishers a useful and error-free product (Art. 6 (1) (f) GDPR)
Deliver and present advertising and content Certain information (like an IP address or device capabilities) is used to ensure the technical compatibility of the content or advertising, and to facilitate the transmission of the content or ad to your device.

We are unable to combine the data we receive in a way that would enable us to personally identify users and we do not combine the data with any third-party data that would enable us to do so.

2.3 Data recipients.

VGE only discloses data to other parties if this is necessary for the implementation of campaigns or other purposes listed in this privacy notice, or if another legal basis for the disclosure of data exists. The collection and processing of usage data by the mobile app Publishers are controlled by the respective Publishers. 

In the context of the serving of ads, data are exchanged between VGE and partner advertisers on the bid request level (to get an ad) or in aggregated form for reporting and fraud analysis. Partner advertisers include demand side platforms, ad-exchanges and advertisers.  This might include the following information on the bid request level:

• device information (device model, platform, operating system version, browser details)
• targeting information (county, city, hyperlocation when allowed to be collected)
• user information (such as device ID, hashed device ID, age, gender and interests, when allowed to be collected).

If VGE uses its own external service providers (e.g. data centers), the service providers may only use the data to fulfill their task. All service providers have been carefully selected and commissioned. They are bound by the instructions of VGE and are regularly checked. In cases where data is processed in countries outside the European Union, appropriate safeguards are always in place to protect data subjects, such as Adequacy Decisions by the European Commission or Standard Contractual Clauses (SCCs)

2.4 Joint controllership

VGE is a service provider, so we work with Publishers to process data. With some of these Publishers, we are joint controllers within the meaning of data protection law (Art. 26 GDPR). This joint controllership generally relates to the collection and transfer of data to us. If we are joint controllers, we and the Publishers have divided certain tasks among ourselves. The division is as follows:

2.4.1 We provide the Publisher with a technical solution that the Publisher integrates into its apps. This technology enables the data described in this policy to be collected. We are also supporting the Publishers, in the processing of enquiries from data subjects.

2.4.2 The Publisher obtains consent where necessary and implements transparency information towards you. They pass this information on to us to communicate the scope and permissibility of the data processing.

2.4.3 The Publishers and VGE will ensure that the necessary data security is in place. Both we and the Publishers will also fulfil our reporting and notification obligations individually but will support and inform us to the extent necessary.

2.4.4 You can exercise your rights as a data subject as described below (see section 3) both against us and against the Publisher. We and the Publisher are liable for any processing that does not comply with the provisions of the GDPR in accordance with Art. 82 GDPR.

If you have any further questions on the topic of joint controllership, we will be happy to provide you with further information on our cooperation with certain Publishers. Please contact [email protected].

2.5 Retention period.

The collected data are stored for as long as the usage data and data about interactions with ads and installations of new apps are required for the described purposes. After that, the data are deleted or completely anonymized. We will further delete personal data immediately when the Publisher informs us that the user has withdrawn consent. We will, however, retain and use information as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

3. Users’ rights

If VGE is acting as the controller, users have the following rights regarding their personal data:

3.1 Right to access information about the processing of their personal data by VGE. In this regard, VGE will explain the data processing to you as the user and provide you with an overview of the data stored about you. For this purpose, you may also contact the Publisher. Whenever needed and upon request, we will assist the Publisher. 

3.2 If data stored by VGE is incorrect or no longer up to date, you have the right to have this data corrected. 

3.3 You may also demand that your data be erased. Should the erasure not be possible in exceptional cases due to other legal regulations, the data will be blocked so that it is only available for that legal purpose. 

3.4 You may also have the processing of your personal data restricted, if for example, you have doubts as to the accuracy of the data. 

3.5 You also have the right to data portability, which means that on request VGE will send you a digital copy of the personal data you have provided. 

3.6 You also have the right to object to data processing, insofar as this is based on legitimate interests pursuant to Art. 6 (1) (f) GDPR. In particular, you can object to the processing of your data for advertising purposes at any time. The opt-out function described below can be used for this purpose at any time. 

3.7 You also have the right to withdraw your consent for us to process your personal data. To do this, please follow the Publisher’s instructions.

3.8 You also have the right to complain to the data protection supervisory authority responsible for VGE (Berlin Commissioner for Data Protection and Freedom of Information, Alt-Moabit 59-61, 10555 Berlin) or to your competent authority. You are also free to contact your local data protection authority, which will then forward your request to the competent authority.

4. Opt-out

If you no longer wish to receive targeted in-app advertising that is deployed based on VGE’s Technology, you may do so through the device-level advertising preference setting available in the settings menus of your iOS and/or Android devices.

Android Users (version 2.3 and above)

To use the “opt-out of interest-based advertising” option, follow the instructions provided by Google here: Google Play Help.

iOS users (version 6 and above)

To use the “Limit Ad-Tracking” option, follow the instructions provided by Apple here: Apple Support Center

Please note that these are device settings and will disable interest-based ads from all providers, and not just for us. We have decided to offer this way of opting-out, as we estimate users will either want to receive interest-based advertising or no interest-based advertising at all. The above-described way is most efficient to achieve that goal.

You may also request deleting your data or opt-out of targeted in-app advertising via e-mail to [email protected].

5. Changes to this Privacy Policy

We reserve the right to change or update this Privacy Policy at any time in accordance with the currently applicable data protection regulations. This website always contains the latest version of the VGE Technology Privacy Policy.