ADL-INNET – “Privacy Policy”

 Last Updated: July 15, 2020

ADL-INNET Consumer Services Privacy Policy

ADL-INNET knows that you take your privacy seriously. We do, too. We seek to be transparent about our data practices and give you control over the information we collect about you. This Consumer Services Privacy Policy covers ADL-INNET and its affiliates and subsidiaries.

The Consumer Services include our websites (the “Sites”), our mobile applications (the “Apps”), and other online services that we own or control (collectively, the “Consumer Services”). This Privacy Policy does not apply to our third party business partners or data suppliers.

This Policy also describes applicable data protection rights including a right to object to some of our processing.

To read our entire policy, see below.

  1. What Data Does ADL-INNET Collect

Data You Provide To Us:

We collect data that you provide to us when you create an account, such as full name, email address, phone number, birthday, gender, the city in which you created your account, and, where applicable, your social media username and other data if you create an account using third party log-in credentials (please see “Data Received From Third Parties” below).

We may also collect other data you provide when you use the Consumer Services, including pictures you upload, messages you send through the Apps, searches, likes, follows, check-ins, tips, survey responses, demographic information, and any other data that you voluntarily provide to us.

Data Collected Automatically When You Use Our Consumer Services:

If you opt in to sharing your location with us, we automatically receive data about your precise location (e.g., latitude-longitude coordinates) whenever you use the Consumer Services (e.g. open our mobile apps, visit our website, etc.). If you opt in to have background location on in our Apps (google places API) we will collect data about your address location when you are not using the Apps and when the Apps are closed.

We also collect additional data about you when you use the Consumer Services. For example:

  • data about how you interact with the Consumer Services, such as your search words, page views, date and time of interactions, time spent on each page, or posts you make;
  • device information, such as your hardware model, operating system and version, unique ID and device data such as device identifiers, IP address, sensor data, browser type, language, and wireless network, mobile device name, types of mobile apps installed; and
  • data from cookies, pixels and other technologies, such as cookie ID, advertising ID or other unique advertising ID, web beacons, and local storage. You can control certain types of cookies through your browser settings or other tools.

You may review our Cookie Policy for further information.


  1. How Is My Data Used By ADL-INNET?

To Operate, Maintain and Improve The Consumer Services

We use your data to operate, maintain the Consumer Services, and our business, and to understand you better and personalize the Consumer Services. In addition, if you use the Consumer Services when you are not logged into your ADL-INNET account, when you subsequently log in to your ADL-INNET account, we combine data collected while you were not logged in.

Some features and functionality in our Apps require that you provide your location. If you have location services turned on, whenever you use our Apps on your mobile device, we collect and use your geo-coordinates (e.g. latitude and longitude) to tailor the Consumer Services to your current location. We will only process your location with your express permission. If you have persistent background location turned on, we will obtain your device’s location even if you are not using the Apps. Your location is never shared with others, except with your consent or as permitted under this Privacy Policy.

We use various technologies to determine your precise location, such as the location services of your operating system or browser, sensor data from your device (e.g. magnetometer, barometer, gyroscopes, accelerometers, compasses, Bluetooth data, beacon data, Wi-Fi access points, GPS data, and cell tower data), and other data that may help us understand your precise location.

If you have opted-in to sharing your background location with us in our Apps, you may remove your permission at any time by going into your operating device settings and toggling off background sharing.

We also use your data to improve the Consumer Services and our business, conduct research and development, perform analytics, develop and offer new products and service, and to infer certain details about you, including details about you, your interests and whether separate devices (e.g. mobile phones, tablets, and/or TVs) are owned by you or by members of your household. For example, we may customize the Consumer Services to allow you to add friends from your device’s contact list who are also using the Consumer Services or, if applicable, your Facebook, Google or Twitter account, if you have opted to connect these accounts to your ADL-INNET accounts). We do not store your contact lists. As another example, we also use your data to help us map Locations (as defined below). For example, we may use device signals to determine that a particular device is within a particular venue. Additionally, if you consent to sharing crash data (when the Apps crash) with us, we may use that data to help us analyze the cause of the crash and improve the Consumer Services.

Communicate With You

We use your data to communicate with you by email, text (if you opt-in), or in our Apps, about new product offerings, updates to the Consumer Services, or anything else we think may be of interest to you. To opt out of receiving marketing communications, please see the “Unsubscribe from Marketing Emails and Text Messages” section of this Privacy Policy below.

Rewards, Contests and Sweepstakes

We may use your data, including your completed surveys, to enable you to earn points and administer your participation in contests and sweepstakes. If you enter a sweepstakes, we will use certain information associated with your account, such as your name and email address, to run the sweepstakes and fulfill prizes to you.

Protection of Our Rights

We may use your data to protect the rights, property or safety of ADL-INNET, the Consumer Services, our users and employees, or any third party. For example, we may use your data to protect against identity theft, prevent fraud or other criminal activity, claims or other liabilities. We may also use your data to comply with and enforce applicable legal requirements, relevant industry standards and our policies, including this Privacy Policy and our Terms of Service.

Our Products

We use your data in our business products and services (“Products”) that we offer to our partners. In particular, we receive data from unaffiliated apps and websites, online advertising services, and our partners, which we may use to send you advertisements that are tailored to your interests. The data collected for this purpose includes data about how you interact with the Consumer Services or with unaffiliated websites and apps, device data, and data from cookies, pixels or other similar technologies.

We combine the data described above with demographic data, location and other interest-based segment data obtained from third parties, including data obtained from the Enterprise Services to provide our Products.

  1. When Is My Data Shared?

We may share certain data about you as further described in this Consumer Services Privacy Policy or when you have given us consent to do so.

Data That May Be Shared With Other Users

When you use the ADL-INNET Apps and Sites, your authorized friends may see some of your data (e.g. name, profile photo, hometown, users you are following, your followers, and other information you post). When you communicate using the ADL-INNET Apps and Sites, such as when you direct message your friends or check-in to a store, restaurant or a location (each a “Location”), your friends may see this data. You can always control what you want visible to others, including your friends, in your “Settings”.

Publicly available data includes your public profile, tips, likes, saves, photos, lists you create and follow, badges/stickers, mayorships, and lists of followers. Public data may be searchable by search engines and be shared with third parties, including through our Products.

Data That May Be Shared With Affiliates, Service Providers and Partners

We may share your data with our affiliated entities, and service providers that perform services on our behalf, such as cloud storage, IT services, marketing, analytics and search engine and other software services. These service providers may be located in countries other than the country in which the information originally was collected, such as the United States and Canada. We do not authorize our service providers to retain, use or disclose the data except as necessary to perform services on our behalf or comply with legal requirements.

In addition, when we partner with a business, we may share data by sharing a mobile advertising identifier and other data, or we may share Data in an aggregate form. We may also assist our business partners in combining the data we obtain when you use the Consumer Services with the data we receive from those business partners about online or offline advertisements that you may have viewed (including on unaffiliated apps, websites, and billboards). We do this so that our partners can serve targeted ads, measure the effectiveness of their ad campaign, and perform analytics. We do not share raw location history. We may also share data to our developer community or third parties for analytical or other purposes.

Data That May Be Shared With Our Affiliates and Subsidiaries

We may share data with our affiliates and subsidiaries in order to improve the Consumer Services, develop and offer our Products, and for other purposes.

Compliance with Law, Protection of Rights and Corporate Events

We may share data (i) if we are required to do so by law or legal process (such as a court order or subpoena); (ii) in response to requests by government agencies, such as law enforcement authorities; (iii) to establish, exercise or defend our legal rights; (iv) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (v) in connection with an investigation of suspected or actual illegal activity; or (vi) to protect the rights, property, or safety of ADL-INNET and our products and services, our employees, or users and others.

We may also share data as part or in anticipation of a business sale, merger, consolidation, investment, change in control, transfer of substantial corporate assets, reorganization, liquidation, or similar business transaction or corporate event.

When You Consent

We will also share your data with your consent.

  1. What About Cookies and Similar Technologies?

We may use technologies like cookies, pixels, web beacons, local storage and other automated technologies on our Sites, in our emails, within our Apps, and sometimes in third party apps that use our APIs or SDKs to provide you with a range of products and services. We use these technologies for a number of purposes, such as for authentication, security, preference settings, in our Products for advertising, measurement and analytics.

You can control cookies through your browser settings and other tools. If you reject cookies, this could affect the availability and functionality of the Consumer Services. For more information, including the types of cookies and similar technologies found on ADL-INNET, please read our Cookie Policy.

Third-Party Analytics

On our Consumer Services, we use third-party analytics services, such as those of Google Analytics. The service providers that administer these analytics services use cookies and other automated technologies to collect data (such as IP addresses, entity site location addresses, and other device identifiers) to evaluate, for example, use of our Consumer Services, google places, and to diagnose technical issues. To learn more about Google Analytics, please visit

Interest-Based Advertising

Through our Consumer Services, both we and certain third parties (such as our business partners) may collect information about your online activities to provide you with advertising about products and services tailored to your individual interests. You may see our ads on other websites or mobile apps because we use third-party ad services. Through such ad services, we can target our messaging to users considering demographic data, users’ inferred interests and browsing context. These services track users’ online activities over time and across multiple online services by collecting information through automated means, including through the use cookies, web server logs, web beacons, device identifiers and other similar technologies. The ad services use this information to show ads that may be tailored to users’ interests. The information ad services may collect includes data about users’ visits to our Consumer Services and other websites and apps that participate in the relevant ad services, such as the pages or ads viewed and the actions taken on the websites or apps. This data collection takes place both on our Consumer Services and on unaffiliated third-party websites and apps that participate in these ad services. This process also helps us track the effectiveness of our marketing efforts.

  1. How do I Access or Delete My Data?

You may access and update your data at any time through the “Settings” tab in your ADL-INNET or profile account. You may also delete your data and account at any time on our Sites by clicking on the “Delete Your Account” link in your “Privacy Settings” page through your web account. If you delete your data, your profile, including your check-in history, tips and photos, badges and stickers received will be removed from the Consumer Services, and you will no longer be able to access such data. We will not be able to restore your account once it has been deleted. Deletion of your account may not be immediate. Residual copies of your personal information or posts may remain on backup media for a short period of time thereafter.

If you wish to delete your account, you can do so by requesting an account deletion from the in-app “Contact Us” form or sending an email to

We may also retain data as required by applicable law and we may retain data that has been anonymized or otherwise does not constitute or contain personal information.

If you have questions about accessing, updating, or deleting your data, please email

  1. Unsubscribe from Marketing Emails and Text Messages
  • By Email:You can opt out of marketing or promotional emails at any time by adjusting your preferences in your “Settings” in the Apps or here, if you are logged into your web account. You may also unsubscribe from marketing emails by following the instructions in the email. Please note that you cannot opt out of service or legal notices.
  • By SMS:If you have opted in to receive SMS messages, you can always unsubscribe at any time by texting STOP in response to a message or by following the instructions in the SMS.
  1. Personal Information Retention

To the extent required by applicable law, we keep the personal information you provide for the duration of our relationship, plus a reasonable period thereafter to comply with the applicable statute of limitations and other applicable laws.

  1. How We Protect Personal Information

We maintain administrative, technical and physical safeguards designed to protect personal information we obtain through the Consumer Services against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

  1. Children under 18

Our Consumer Services are intended for a general audience and are not directed at children. We do not knowingly collect personal information online from individuals under the age of 18 or such other age as may be directed by applicable law.

  1. Your Rights

Subject to applicable law, you may have a number of rights regarding the processing of your Personal Data, including:

  • the right to request access to, or copies of, your personal data that we process or control, together with information regarding the nature, processing and disclosure of that personal data;
  • the right to request rectification of any inaccuracies in your Personal Data that we process or control;
  • the right to request:
    • deletion of your personal data that we process or control; or
    • restriction of processing of your personal data that we process or control;
  • the right to object, to the processing of your personal data by us or on our behalf;
  • the right to have your personal data that we process or control transferred to another data controller, to the extent applicable;
  • the right to withdraw where we process your personal data on the basis of your consent, and
  • the right to file a complaint with a Data Protection Authority regarding the processing of your personal data by us or on our behalf.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Privacy Policy, or about our processing of your personal data, please use the contact details provided in the Contact Us section.

These rights may be limited in certain circumstances, for example if fulfilling your request would (i) reveal personal data about another person, (ii) infringe the rights of a third party (including our rights), (iii) cause us to delete information that we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in local implementing legislation. We will inform you of relevant exemptions we rely upon when responding to any request you make.

You have the right to access your personal data. In compliance with the Principles, ADL-INNET commits to resolve complaints about our collection or use of your personal data. Individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at ADL-INNET has further committed to refer unresolved Privacy Shield complaints, an alternative dispute resolution provider located in the EU and Africa. If you do not receive a timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact us for more information.

You have the ability, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms.

African Countries Trade Commission has jurisdiction over ADL-INNET’s compliance with Privacy Shield. This is in addition to our requirement to disclose personal data to public authorities upon the receipt of a lawful request, including requests made in relation to national security or law enforcement requirements, as discussed above in this Privacy Policy.

If we transfer your personal data to a third party acting as our agent, we remain responsible for how that personal data is processed. This means that we will remain liable under the Principles if any third party acting as our agent processes your personal data in a manner inconsistent with the Principles, unless we were not responsible for the event giving rise to the damage.

Who is Responsible for Your Data?

ADL-INNET is a data controller for all data collected under this Consumer Services Privacy Policy.

  1. Changes to this Privacy Policy?

ADL-INNET may amend this Consumer Services Privacy Policy from time to time. We encourage you to regularly check this page to review any changes we might make in accordance with this Consumer Services Privacy Policy. We will indicate at the top of the Privacy Policy when it was most recently updated. If we make material changes in the way we use your data, we will notify you by posting an announcement on our Sites or Apps, or by sending you an email (if we have your email).

  1. Contact Us

If you have any questions or concerns regarding this Privacy Policy, please send a detailed message to our Data Protection Officer: We will make every effort to resolve your concerns.