Data Sharing Addendum
Updated October 28, 2026
Draft for review before paid launch. Business details and these policies are being finalized.
Scope
This Data Sharing Addendum forms part of the SDK License Agreement (EULA) and the Terms of Service between Immersed Advertising and each developer that registers a game. It applies whenever a registered game uses the SDK. If it conflicts with the SDK License Agreement or the Terms about player data, this Addendum controls.
Roles
For player data collected through your game, you and we each decide our own purposes, and each of us is a separate controller (a business, under US state laws) for its own processing. For players in the European Economic Area, the United Kingdom or Switzerland, you and we are joint controllers for collecting that data in your game and sending it to our servers; after it reaches our servers, we are a separate controller for our own processing. Neither of us processes player data on the other's behalf or acts as the other's agent.
Data covered
The SDK sends a random per-launch session identifier, the platform, view measurements and timestamps, and stores nothing on the player's device. When location matching is on (it is always off for players in the EU, EEA and UK), our servers estimate the player's country and state or province from the IP address of the ad request and store only that; we never store IP addresses, user agents or device identifiers. Do not send us any other personal data through the SDK or our interfaces, such as device or advertising identifiers, names, email addresses, account IDs, precise location or data about players you know to be under 13.
Purposes
We use player data only to deliver and select ads, including by approximate location where location matching is on; to measure views, calculate charges and produce reports; to detect and prevent fraud, invalid traffic and abuse; to keep the service secure and working; and to comply with law. We do not sell player data for money, use it to build profiles for other purposes, give it to advertisers in a form that identifies a player or device, or knowingly combine it with a player's name or contact details.
Your responsibilities
Before your game shows our ads, its privacy notice must explain the data above, its purposes and that it goes to Immersed Advertising, and link to our Privacy Policy. If your game lets players turn location matching off, apply their choice with ImmersedAdsPrivacy.SetPersonalizedAdsConsent(false) on every launch. Keep your game's declared audience and location-matching setting accurate, and do not modify the SDK to send device identifiers or other personal data, or to ignore a player's choice.
Our responsibilities
We never estimate location for players in the EU, EEA and UK, and stop estimating it whenever your dashboard setting is off, your game's audience is under 13, or the SDK reports that location matching is off for a player. We keep country, state and session details for no longer than 180 days, then erase them, keeping only the counts and amounts they produced, and we never keep IP addresses, user agents or device identifiers. We protect player data with reasonable administrative, technical and physical safeguards, including access controls and encryption in transit. We process player data with at least the level of privacy protection the applicable privacy laws require, and will tell you if we can no longer meet those obligations, so that you can take reasonable steps to stop and remedy any unauthorized use, including turning location matching off for your game.
Player requests
Each of us handles requests addressed to it. If a player asks you to stop location matching, or to delete or access their data, turn location matching off for that player in the SDK and, within 10 business days, forward to eliott.mault@icloud.com any part of the request that concerns data we hold. We will help you answer requests about data we hold. Players in the EEA, UK and Switzerland may contact either of us, and the party contacted will promptly inform the other.
Security incidents and regulators
If either of us becomes aware of a security incident affecting player data collected through your game, it will tell the other without undue delay and, where feasible, within 72 hours, with the information the other reasonably needs for its own notification duties. Each of us is responsible for the notifications the law places on it, and we will cooperate on any that concern both of us. If a regulator or court asks either of us about this data, that party will tell the other where legally allowed, and both will reasonably cooperate.
International transfers
Our servers are in the United States. For player data from the EEA, the Standard Contractual Clauses adopted by the European Commission in Decision (EU) 2021/914, Module One (controller to controller), are incorporated into this Addendum, with you as data exporter and us as data importer, and the transfer details are those described in this Addendum. For the UK, the UK International Data Transfer Addendum to those Clauses applies, and for Switzerland the Clauses apply with the amendments Swiss law requires.
Liability, term and changes
The liability limits and third-party claims provision in the Terms of Service apply to this Addendum. Each of us is responsible for its own breaches of privacy law, and nothing here limits a player's rights against either of us. This Addendum applies while any of your games uses the SDK or we hold player data collected through them, and its security, request, incident and regulator terms continue until that data is erased. We may update it to reflect changes in law or the SDK; material updates are presented for renewed acceptance like our other policies.