AVOW End User Privacy Notice

Information for users of mobile devices and mobile applications in connection with advertising and app distribution delivered through AVOW.

Version: EUPN202601

Effective: 10 November 2026

1. About this notice

AVOW GmbH (“AVOW”, “we”, “us”) provides mobile advertising and application distribution services. We work with advertisers, meaning the companies whose applications are advertised or distributed, and with media partners, including mobile device manufacturers and application publishers, who make advertising space available to us.

We do not operate any mobile application of our own. We have no software, code or tracking technology on your device. We have no account relationship with you and, in the ordinary course, no means of contacting you.

We do receive a limited amount of information relating to your device from the advertisers and media partners we work with. This notice explains what that information is, where it comes from, what we do with it, and what rights you have.

What this notice does not cover

Visitors to our website at avow.tech. That is covered by our website privacy policy at https://www.iubenda.com/privacy-policy/16171241
The processing carried out by the advertiser whose application you installed, by that advertiser’s measurement provider, or by the manufacturer of your device or the publisher of the application in which an advertisement was shown. Each of those parties handles your data for its own purposes and under its own privacy notice. Please consult theirs as well as this one.

2. Who we are

AVOW GmbH

Oranienstraße 185

10999 Berlin, Germany

Data protection contact and Data Protection Officer: privacy@avow.tech

3. Our role

Our role under the General Data Protection Regulation (“GDPR”) depends on the activity concerned and on our agreement with the advertiser or media partner involved.

For most of what we do, we act on the documented instructions of an advertiser or a media partner. That party decides why and how the data is handled, is responsible for the legal basis for it, and informs you about it through its own privacy notice.

For the limited set of purposes described in section 6 below, we determine the purpose ourselves and act as a controller. In some engagements, our agreement with an advertiser or media partner provides that each of us acts as an independent controller of the data it receives. Where either is the case, the purposes and legal bases set out in section 6 apply to our handling of the data.

4. Where the information comes from

We do not collect any information from your device. We receive it from:

advertisers whose applications are advertised or distributed through our services, and from the mobile measurement providers those advertisers appoint for that purpose, such as AppsFlyer, Adjust, Branch, Kochava or Singular; and
media partners, including mobile device manufacturers and application publishers, who make advertising space available to us.

The categories of information we receive, and the level of detail, are determined by those parties and not by us.

5. What information we handle

Depending on the campaign, we may receive:

the advertising identifier for your device (the Identifier for Advertisers on Apple devices, the Advertising ID on Android devices);
the IP address of your device;
the country, region and city in which an application was installed;
the date and time of the installation;
technical information about your device and its operating system;
browser type and version, mobile network operator and network status;
events occurring within an application after installation, such as a registration or a purchase, where the advertiser chooses to pass these to us;
for rewarded campaigns, the click identifier generated by the rewarded media partner concerned.

We do not receive your name, email address, telephone number or postal address.

We do not receive special categories of personal data within the meaning of Article 9 GDPR.

6. What we use the information for, and on what legal basis

Where we act on the instructions of an advertiser or a media partner, the legal basis for the processing is established by that party, not by us, and you should consult its privacy notice.

Where we act as a controller, we rely on our legitimate interests and those of the advertisers and media partners we work with, under Article 6(1)(f) GDPR, for the following purposes.

Purpose	What this involves	The legitimate interest
Campaign delivery checks	Confirming that an advertisement was delivered in accordance with the parameters of the campaign, for example that a device was located in a country included in the campaign.	Delivering the service we are contracted to provide, and not charging an advertiser for delivery outside the agreed parameters.
Fraud and invalid traffic checks	Identifying activity that is automated, artificially generated or otherwise not genuine. We act on indicators produced by the advertiser’s measurement provider or by specialist fraud detection tools.	Preventing fraud. Recital 47 GDPR recognises processing for fraud prevention purposes as a legitimate interest.
Billing and settlement	Calculating and verifying the amounts payable between us, our advertisers and our media partners, and producing the records that support invoicing.	Operating our business and meeting our accounting and tax record-keeping obligations.
Disputes and legal claims	Investigating and resolving disputes about campaign performance or amounts payable, and establishing, exercising or defending legal claims.	Protecting and defending our legal position.

What we do not do

We have assessed the effect of this processing on you, and the following limits form part of that assessment. We do not:

build profiles of individual people;
target or retarget individuals on the basis of behaviour observed across different advertisers;
combine this information with data from other sources in order to learn more about you;
sell this information, or make it available for anyone else’s advertising purposes;
use this information to train machine learning or artificial intelligence models;
make any decision that produces legal effects concerning you or similarly significantly affects you, and we do not carry out automated decision-making within the meaning of Article 22 GDPR.

Information read from your device

Information is read from your device by the application you installed, by that application’s measurement provider, or by the manufacturer of your device at device or operating system level. Where consent is required for that under Article 5(3) of Directive 2002/58/EC, as implemented in national law including section 25 of the German Telekommunikation-Digitale-Dienste-Datenschutz-Gesetz (TDDDG), it is for the party reading the information from your device to obtain that consent. We do not read information from your device.

7. Who we share the information with

The advertiser whose application was advertised, and the measurement provider that advertiser has appointed.
The media partner on whose advertising space the advertisement was shown, where confirmation that an installation or an event has occurred is needed in order to calculate what is payable.
For rewarded campaigns, the rewarded media partner, so that it can verify the qualifying action and pay the reward. Rewarded media partners are responsible, as controllers in their own right, for their relationship with you, for your account with them and for the reward.
Professional advisers and auditors, and public authorities, where we are required to disclose by law or where disclosure is necessary to establish, exercise or defend legal claims.

We also use the following service providers, who handle the information only on our instructions:

Provider	Service	Location
Everflow Technologies Inc.	Tracking, reporting and analytics platform	United States
Amazon Web Services EMEA SARL	Cloud hosting and storage	Luxembourg
Google Cloud EMEA Limited	Email, file storage and collaboration	European Union
Anthropic PBC	AI services used for data visualisation and analysis. The data is not used to train models.	United States

The current list is maintained at https://avow.tech/advertiser-dpa.

8. Transfers outside the European Economic Area

Some of the recipients listed above are located outside the European Economic Area. Where we transfer personal data to them, we rely on a transfer mechanism permitted under Chapter V GDPR, which in most cases is the standard contractual clauses adopted by the European Commission.

You may request information about the mechanism applying to a particular transfer by writing to privacy@avow.tech.

9. How long we keep it

We delete the information from our own systems two months after the contract with the advertiser whose app you have installed is terminated.

We keep the records required for invoicing, accounting and tax for as long as German commercial and tax law requires, currently up to ten years under section 257 of the Handelsgesetzbuch and section 147 of the Abgabenordnung. Those are financial records. They do not contain advertising identifiers or IP addresses.

Where an advertiser has granted us access to its own measurement platform, the data held in that platform belongs to the advertiser, is retained in accordance with the advertiser’s own retention policy, and cannot be deleted by us. It is for the advertiser to withdraw our access.

10. Your rights

Subject to the conditions in the GDPR, you have the right to:

obtain confirmation of whether we hold personal data relating to you and obtain a copy of it (Article 15);
have inaccurate data corrected (Article 16);
have data erased (Article 17);
have processing restricted (Article 18);
receive the data in a portable format (Article 20);
object at any time, on grounds relating to your particular situation, to processing we carry out on the basis of our legitimate interests (Article 21). If you object, we will stop processing unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing is needed to establish, exercise or defend legal claims.

An important practical point

The information we hold relates to a device, not to a named person. We hold no name, email address or other contact details and we cannot identify you from them.

To locate and act on your data we need the advertising identifier for the device concerned, together with the application and the approximate date. You can find your advertising identifier in your device settings. If you cannot provide it, Article 11(2) GDPR applies and we may be unable to comply with a request under Articles 15 to 20, in which case we will tell you so.

Please send requests to privacy@avow.tech.

Complaints

You may lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work, or the place of the alleged infringement. Our lead supervisory authority is:

Berliner Beauftragte für Datenschutz und Informationsfreiheit

Alt-Moabit 59-61, 10555 Berlin, Germany

11. The controls available on your device

Independently of the rights above, your device gives you direct control over the advertising identifier:

On Android: Settings, then Google, then Ads, where you can delete or reset your advertising ID and opt out of ad personalisation.
On Apple devices: Settings, then Privacy & Security, then Tracking, where you can stop applications requesting permission to track you.
The consent or permission settings offered to you by the application you installed, or by the manufacturer of your device.

If you delete or reset your advertising identifier, information we received before you did so can no longer be linked to your device.

12. Why we have not contacted you individually

We did not obtain this information from you and we hold no contact details for you, so we have no means of providing this information to you individually. Providing it individually would be impossible, or would require us to collect contact details we do not have and do not need.

In those circumstances Article 14(5)(b) GDPR requires us to take appropriate measures to protect your rights, including by making this information publicly available. Publishing this notice is that measure.

13. Changes to this notice

We may update this notice. The version number and effective date at the top of the document show when it was last changed. Earlier versions are available on request.

14. Contact

Questions about this notice, or requests concerning your personal data:

privacy@avow.tech

AVOW GmbH, Oranienstraße 185, 10999 Berlin, Germany