EU Privacy Policy

xAd, Inc. dba GroundTruth –Website & Ad Platform Privacy Policy

The details of GroundTruth’s privacy policy are below. If you have questions about our mobile and website security or our privacy policy online, please email

This privacy policy applies to our corporate website and, or “Website”, as well as to our mobile advertising product and mobile advertising landing pages. This privacy policy describes how GroundTruth collects, uses, shares and secures information, and describes your choices regarding use, access and correction of your personal data.

EU-U.S. Privacy Shield

xAd, Inc. dba GroundTruth participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. GroundTruth is committed to subjecting, and does subject, all personal data received from the European Economic Area (EEA), in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List:

GroundTruth’s Website and Ad Platform Privacy Policies below describe the types of personal data GroundTruth collects, the types of third parties to which it discloses personal data and the purposes for which it does so. Residents of the EEA have the right to access the personal data that GroundTruth maintains and, in some cases, may have the right to correct or amend information that is inaccurate or has been processed in violation of the Privacy Shield Principles, to the extent allowed by law. To exercise this right, contact us at For information on opting out of interest-based advertising delivered by GroundTruth, please see the Choice section of this policy below.

GroundTruth is responsible for the processing of personal data it receives, under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. GroundTruth complies with the Privacy Shield Principles for all onward transfers of personal data from the EEA, including the onward transfer liability provisions.

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

Residents of the EEA with inquiries or complaints regarding this Privacy Policy should first contact GroundTruth via the contact information listed in the Website Privacy Policy below. If your privacy concern is not resolved satisfactorily, please contact our US-based third party dispute resolution provider (free of charge) at Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Legal Basis of Processing Data

GroundTruth’s legal basis for processing your personal data is to: carry out our contracts; abide by law; and based on your consent.  To the extent that processing is based on consent, you have the right to withdraw consent at any time.  We also may process your personal data when it is in our legitimate interests to do so and when these interests are not overridden by your rights.  For example, we might process personal data for: direct marketing; preventing fraud; sharing data among subsidiaries for internal purposes; ensuring network and information security; reporting criminal acts or threats to public security; establishing legally binding agreements with third parties; billing third parties; and taking internal measures to improve website functionality.



Effective Date: 23 May 2018

This privacy policy explains how xAd, Inc. dba GroundTruth (“we,” “us,” “our”) and our affiliates and subsidiaries collect, use and share information via our mobile advertising service and mobile advertising landing pages (“Services”).


Overview of GroundTruth’s Services

GroundTruth is a mobile advertising platform specialising in location powered mobile ads. Our Services combine data, technology and strategy to help advertisers reach the audiences most likely to be interested in their products or services.

If you visit the mobile website or use a mobile app of one of our platform members, that property will have its own privacy policy and practices. You will need to refer to the member’s privacy policy for information about their data collection and use practices.

GroundTruth adheres to the Digital Advertising Alliance’s (“DAA”) self-regulatory principles, the Digital Advertising Alliance Canada’s (“DAAC”) self-regulatory principles, the Internet Advertising Bureau (“IAB”) UK’s Good Practice Principles for Online Behavioural Advertising and the European Interactive Digital Advertising Alliance’s (“EDAA”) self-regulatory principles.

Data Collection & Use

We may collect various types of information, including personal data, from mobile devices using cookies, scripts, web beacons, software development kits (“SDK”), or other similar techniques. These technologies are used to collect digital actions of users that visit and use mobile websites and apps, or interact with ads presented in mobile websites and apps of our platform members. We also receive other data (e.g., demographic information) from third parties or through analytical techniques that we combine with the data we collect or derive through the Services.

The data we collect can include a device identifier, browser and operating system type and version, device type and other data from or about a mobile device including precise location data, as well as information about users’ web viewing, app use, and demographic data collected by other parties such as gender or year of birth. This data may be collected over time across different apps, websites, browsers or devices. We may also receive data related to the location of a mobile device from platform members and other parties. We may also derive physical address information and infer other general or precise location-related information we receive or collect from mobile devices. We retain data only as long as we have a legitimate business purpose to retain such data in accordance with our data retention schedule and as otherwise required by applicable law.

We may use data for purposes including analytics; research; reporting; attribution; Service enhancements and other business operations; predicting possible relationships among different browsers and devices; differentiating and/or associating multiple device users as well as associating devices or users with locations such as a household or workplace; frequency capping; and in multiple ways to make ads more relevant, whether by automated or non-automated means using algorithms and other methods to evaluate and analyze the data. For instance, we may use the location related data to present ads in real-time from a local business or use that and other data we collect to deliver ads that the user may find more relevant to their interests. Another example would be using this data to create “segments” – groups of users that are inferred to share similar interests.



We use data collected across different devices and from non-affiliated websites and apps over time to provide advertising relevant to interests inferred from this data for our clients. This form of advertising is known as interest-based advertising. We may also partner with other ad companies to extend our audiences across different browsers and devices for interest-based advertising purposes.


You may download the DAA’s AppChoices mobile app, or the TRUSTe mobile app, on your iOS or Android device in order to exercise choice regarding the collection of mobile application use activity for interest-based advertising on this device by us and other companies that participate in those choice tools. Links to those apps are below:

Location Data Choice: The DAA’s AppChoices tool can also be used to exercise choice regarding the collection and use of precise location data by GroundTruth for interest-based advertising purposes.  iOS and Android users can limit our collection of precise location data from the device on which the setting is set by turning location services off through your device settings.

If you would like to exercise choice regarding our, and for other third parties that participate in the DAA Choice Page, collection of web viewing data from web browsers for interest-based advertising purposes on this device, click here.

When we know you have made a choice on your browser or device using these choice tools, we will stop using data from that browser or device  for interest-based advertising on it. We will also stop using data collected from that browser or device on other browsers or devices associated with it and will stop using data collected from those associated browsers or devices for interest-based advertising on the opted-out browser or device.

You also have the right to access the personal data that we maintain, and in some cases, may have the right to correct or amend information to the extent allowed by law.  Additionally, you also have certain rights to object to or restrict data processing, erase personal data, and make use of data portability.  To exercise these rights, contact us at

Note that electing to opt out from GroundTruth services will not stop advertising from appearing in your browser or apps. It may make the ads you see less relevant to your interests. In addition, note that if you use a different browser or device, erase cookies from your browser, or reset your platform ad identifier, you may need to renew your opt-out choice. In addition, we may still collect data in browsers or apps for non-interest based advertising purposes such as for analytics and reporting purposes, operations, improving our services and frequency capping.


Data Sharing

We may share various types of information we collect, including personal data, and infer about devices and users with our affiliates, third-party partners and agents for advertisement targeting, audience extension across different browsers and device, to make and create offers, for other marketing purposes, to provide reporting to advertisers and clients, to improve our systems and products and for other research and analytical purposes.

We may also share data, including personal data, with third-party contractors and service providers who work on our behalf. We may disclose such data in response to subpoenas, court orders, or other legal process, or to establish or exercise our legal rights and obligations or defend against legal claims. We may also transfer such data in the event of an acquisition or merger with another company, including in the event of bankruptcy.



Our services and this website are not intended for children under the age of 16, and we do not knowingly collect information from children under the age of 16.




Voluntarily Submitted Information on our Websites

This privacy policy applies to our corporate websites and explains how xAd, Inc. dba GroundTruth (“we,” “us,” “our”) and our affiliates and subsidiaries collect, use and share information on, or other website that links to this policy (collectively “Website”). By using the Website you agree to the terms of this Privacy Policy.


Information Collection & Use:

Personal Data

When you use the Website, you may encounter areas that allow you to voluntarily enter personal data, which includes your name, email address, telephone number and mailing address.

You may provide this information to us when you sign up for our newsletter, request information about products, apply for a job, fill out surveys, or otherwise provide personal data to us.

We may use personal data for, among other things:

  • Internal record keeping;
  • Communicating with you about site updates and your inquiries, as well as offering products, content and services that we believe may be of interest to you;
  • Customising the Website; and
  • For purposes disclosed at the time of collection.

If you would prefer not to receive communications from us in the future, please follow the unsubscribe instructions available in each communication.

We may retain your information for as long as necessary in accordance with our data retention schedule to fulfill a legitimate business need, such as to provide you with information or services, comply with our legal obligations, resolve disputes and enforce our agreements.


Usage Information

When you browse our Website we may collect various types of usage information, including, but not limited to, IP address, web pages visited, links clicked, your operating system and browser type and your mobile device identifier. Such information is used for the purposes of operating and improving our Website, analysing demographic and statistical research about website usage, customising offers and monitoring the Website for compliance with our terms of service and the law, as well as other purposes.

This usage information may be collected through various technologies, including but not limited to “cookies.” For more information, please see the “Tracking Technologies” section below.  This usage information may or may not include personal data.


Information Sharing

We will not sell, rent, license, trade or disclose your personal data collected through our Websites to an unaffiliated third party, except with your permission or for circumstances described in this policy. We may share personal and non-personal data in certain circumstances, including sharing with:

  • Third-party service providers that assist us with, for example, our CRM management and infrastructure needs;
  • Our subsidiaries and affiliates;
  • Entities as required by a court order, subpoena, warrant or when otherwise required by law;
  • Entities as part of a sale or merger of all or part of our business, including at bankruptcy;
  • Third parties for our direct marketing purposes; and
  • Entities to protect our rights and the rights of third parties.


Links to Other Websites

The Website may contain links to third-party websites that we do not control, and to which this privacy policy does not apply. We encourage you to read the privacy policy of every website you visit.



We follow generally accepted standards to help protect the personal data submitted to us, both during transmission and once it is received.


Update Personal Data

You have certain rights to access, update, object to, restrict, or request deletion of personal data or make use of data portability. If you wish to do so, contact us at stating that request. We will respond to your request within a reasonable timeframe.


Tracking Technologies

GroundTruth and our partners use cookies or similar technologies to analyse trends, administer the Websites, collect information about use of the Websites and to gather demographic information about our user base as a whole. Users can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our Website or service. To manage Flash cookies, please click here.

We use Google Analytics to better understand how visitors interact with our Websites. This service provides usage information including but not limited to data on where visitors came from, what actions they took on our Websites and where visitors went when they left our Websites. We use this information to improve your experience when visiting our Websites. Please click here to learn more about this service and how to opt out of data collection by Google Analytics.


Digital Advertising

We may partner with ad networks and other ad serving providers (“Advertising Providers”) who serve ads on behalf of us and others on non-affiliated sites. Some of those ads may be personalised, meaning that they are intended to be relevant to you based on information Advertising Providers collect about your visits to this site and elsewhere on the internet over time, as well as from various mobile apps you use, across different devices.

You may visit to learn more about this type of advertising and how to opt out of this type of advertising by companies participating in the Digital Advertising Alliance self-regulatory programme. Additionally, if you would like to opt-out of this type of advertising in mobile apps, you can visit here and download the opt-out app for your device.

GroundTruth adheres to the Digital Advertising Alliance’s Self-Regulatory Principles. Note that electing to opt out will not stop advertising from appearing in your browser or apps. It may make the ads you see less relevant to your interests. In addition, note that if you use a different browser, erase cookies from your browser, or reset your platform ad identifier, you may need to renew your opt-out choice. You can also opt out of browser-based interest-based advertising by us and other companies that offer choice through TrustArcby clicking here, or if located in the European Union you can click here to make choices with respect to companies integrated in the YourOnlineChoices consumer choice platform. Please note you will continue to receive non-interest-based ads.



This Website is not intended for the use of children under the age of 16. We do not knowingly collect personal data from children under the age of 16.


Privacy Policy Changes

We may update this privacy policy to reflect changes to our information practices. If we make any material changes with respect to our practices relating to your personal information, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website before the change becoming effective. We encourage you to review this page periodically for the latest information on our privacy practices.


Contact Us

If you have questions or complaints regarding our privacy policy or practices, please contact us, in our role as data controller, at:

Global Headquarters

One World Trade

60th Floor

New York, NY 10007

Our Data Protection Officer is Christopher Yamaoka, who can be reached at:

If you have an unresolved privacy or data use concern that we have not addressed to your satisfaction, please contact our US-based third-party dispute resolution provider (free of charge) at  You also have the right to lodge a complaint with data protection authority in your country of residence.