1. Scope

This Policy describes ADAPT’s practices as a controller of personal information collected through the Site and through our general business activities (marketing, sales prospecting, vendor management, hiring, and similar operations). It does not address information processed inside the Adlapt application on behalf of a Customer; for that, see the Adlapt Privacy Policy.

2. Information We Collect

2.1 Information you provide to us

• Contact information: name, email address, company name, role, and any other information you send when you contact us, request information, subscribe to updates, or apply for a position.
• Communications: messages and any attachments you send to us by email or through the Site.
• Business-relationship information: information about vendors, partners, investors, and other counterparties (and their personnel) collected in the course of evaluating, negotiating, or maintaining a relationship.

2.2 Information collected automatically

• Site usage: aggregate, privacy-respecting analytics about pages visited and referrers, collected by our analytics provider (see Section 7).
• Ad-campaign telemetry: conversion and audience signals returned to our advertising platform when you arrive via an ad (see Section 8).
• Technical data: IP address, browser type, device identifiers, language preference, and timestamps, to the extent collected by our infrastructure and analytics provider.

2.3 Information we receive from third parties

We may receive limited information from third parties that help us run our business — for example, our advertising platform may report which campaign drove a visit, or a referral source may provide your contact details with your consent.

3. How We Use Information

We use the information described above to:

• operate and improve the Site;
• respond to inquiries and provide information you request;
• send marketing communications you have opted in to receive (you can unsubscribe at any time);
• measure the effectiveness of our content and advertising in aggregate;
• manage relationships with prospects, customers, vendors, and partners;
• recruit and evaluate candidates for open positions;
• secure the Site and prevent fraud or abuse;
• comply with legal obligations and enforce our agreements; and
• establish, exercise, or defend legal claims.

ADAPT does not sell personal information.

4. Legal Bases for Processing (EEA / UK)

If you are located in the European Economic Area, the United Kingdom, or Switzerland, we rely on the following legal bases under the GDPR / UK GDPR:

• Legitimate interests — to operate, secure, and promote our business, balanced against your rights;
• Consent — for non-essential cookies, marketing communications, and advertising measurement where required by law;
• Performance of a contract — to engage with prospects, customers, vendors, and applicants; and
• Legal obligation — to comply with applicable law.

5. How We Share Information

We share information only as described below.

6. Service Providers We Use

The third-party services we currently rely on for the Site and general business operations are listed below. We may update this list as our stack evolves; the most current list will always appear in this Section.

7. Cookies and Analytics

The Site uses a small number of strictly necessary cookies to operate (for example, to remember preferences). The Site does not use third-party advertising cookies for tracking. Analytics on the Site are provided by Fathom Analytics, which is designed to be privacy-respecting and does not use cookies for cross-site tracking or build profiles of individual visitors. If we add additional analytics or tracking technologies in the future, we will update this Policy and, where required by law, request your consent.

8. Advertising

We run advertising campaigns through Google Ads to reach people who may be interested in our products and services. When you arrive on the Site from one of our ads, Google may receive information about that visit (such as the ad you clicked, your IP address, and limited technical data) so we can measure the effectiveness of the campaign. You can control how Google personalizes ads to you at adssettings.google.com and, in supported regions, opt out of personalized advertising via youradchoices.com or youronlinechoices.eu.

9. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Policy, to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Aggregate analytics from Fathom are retained according to Fathom’s standard retention. Marketing contacts are retained until you unsubscribe or ask us to delete your information. Recruiting records are retained for a reasonable period after a hiring decision unless a longer retention is required by law.

10. Security

We use administrative, technical, and physical safeguards designed to protect information against unauthorized access, disclosure, alteration, and destruction, including encryption in transit, role-based access controls, and least-privilege access to our systems. We design our controls to align with the Cybersecurity Maturity Model Certification (CMMC) framework. No security program is perfect, however, and you are responsible for keeping any credentials you use to access our systems secure.

11. International Data Transfers

ADAPT is based in the United States, and our service providers may process information in the United States and other countries. Where required, we rely on appropriate safeguards (such as the European Commission’s Standard Contractual Clauses) for international transfers of personal information.

12. Your Privacy Rights

Depending on where you live, you may have the right to access, correct, delete, port, or restrict our processing of your personal information, to object to processing, and to withdraw consent. To exercise these rights, contact us using the information in Section 16. We will verify your request as required by law and respond within the timeframe required by applicable law. You have the right to lodge a complaint with a supervisory authority in your country of residence.

13. California Privacy Notice

If you are a California resident, the California Consumer Privacy Act (as amended by the CPRA) provides you with the rights described in Section 12, as well as the right not to receive discriminatory treatment for exercising those rights. ADAPT does not “sell” personal information for money. We use Google Ads measurement features that may, under California law, be considered “sharing” of personal information for cross-context behavioral advertising. You can opt out of such sharing by configuring your browser’s Global Privacy Control signal, by adjusting your Google Ad Settings at adssettings.google.com, or by contacting us using the information in Section 16. The categories of personal information we collect, the purposes for collection, and the categories of recipients are described in Sections 2, 3, 5, and 6.

14. Children’s Privacy

The Site is not directed to, and we do not knowingly collect personal information from, children under 16. If you believe a child has provided us with personal information, please contact us and we will delete it.

15. Changes to this Policy

We may update this Privacy Policy from time to time. If we make a material change, we will provide reasonable notice (for example, by posting an updated version on the Site). The “Effective” date at the top of this Policy reflects the latest revision.

16. Contact

ADAPT Technology LLC
Auburn Hills, Michigan, United States
Privacy email: privacy@adapttechnology.com (or steve@adapttechnology.com)