AppLovin

AD TECH & ANALYTICS

LAST UPDATED 27 AUG 2026

OF 100

PARANOIA SCORE

WHAT THE POLICIES SAY

AppLovin Corporation (Nasdaq: APP) is a Palo Alto-based advertising technology company whose software reaches consumers primarily through other companies' apps and websites rather than its own consumer product. The company's privacy policy describes automatic collection of device, app, and browser data — including advertising identifiers, IP address, and device properties — across apps and devices over time, plus e-commerce data such as email addresses, phone numbers, and purchase histories received from merchants. AppLovin says it does not sell data for money and does not collect sensitive personal information, offers a data-deletion app, and retains data typically up to two years. It faces pending U.S. securities class actions and a 2026 Dutch class action alleging unlawful tracking of users including children; both are unadjudicated allegations the company can contest.

TRACK RECORD

1 ENFORCEMENT ACTION

[2026-02-19]

AppLovin's FY2025 10-K discloses pending putative securities class actions (beginning March 2025) and consolidated shareholder derivative suits against the company and executives; the amended complaint alleges materially false and misleading statements about its advertising solutions and financial growth over a class period of November 7, 2024 to March 27, 2025. These are unadjudicated allegations; AppLovin states they lack merit, and a motion to dismiss was pending as of the filing.

sec.gov ↗

TIMELINE

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AppLovin

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RECEIPTS

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COLLECTION

AppLovin's Axon AI page states its ad models continually train on device and network information, data about users' engagement with apps and ads, bid win/loss data from MAX, and advertisers' own data about their users when shared. It also states the models do not ingest 'sensitive personal information' or protected characteristics, and that partners are prohibited from providing children's data.

legal.applovin.com ↗

[2026-02-19] · COLLECTION

AppLovin's FY2025 annual report describes a data flywheel in which growth in advertiser adoption expands the user data available to its Axon AI recommendation engine, which in turn strengthens its advertising products.

sec.gov ↗

[2026-07-21] · COLLECTION

AppLovin's privacy policy states that when a consumer uses an app containing the AppLovin SDK, it may collect device, app, and browser data — including advertising IDs (IDFA/GAID/Amazon Advertising ID), IP address, device make/model/settings, and app session data — and, for its e-commerce ads, merchant-provided email addresses, phone numbers, zip codes, and purchase histories. The policy states retention is typically up to two years.

legal.applovin.com ↗

[2026-02-19] · OWNERSHIP TRANSPARENCY

AppLovin is a public company listed on Nasdaq (APP) whose FY2025 10-K discloses its acquisitions of Adjust (April 2021), Twitter's MoPub business (January 2022), and Wurl (April 2022), and discloses that a multi-class share structure and voting agreement concentrated approximately 67% of shareholder voting power with the Voting Agreement Parties as of December 31, 2025.

sec.gov ↗

[2026-07-21] · OWNERSHIP TRANSPARENCY

AppLovin publishes dated, versioned privacy policies on its legal site, names a Data Protection Officer with a postal address, and states it has certified adherence to the EU-U.S., UK Extension, and Swiss-U.S. Data Privacy Framework principles with the U.S. Department of Commerce, placing DPF-covered processing under FTC enforcement jurisdiction.

legal.applovin.com ↗

[2026-02-19] · SHARING

AppLovin's FY2025 10-K states that data generated by its Adjust measurement subsidiary is not shared with AppLovin or used to optimize its Axon recommendation engine unless a customer directs it — a stated internal segregation between its attribution business and its ad-targeting business.

sec.gov ↗

[2026-07-21] · SHARING

AppLovin's privacy policy states it shares information with third-party advertising partners — advertisers, ad networks, exchanges, demand-side platforms, merchants, and measurement/attribution partners — for interest-based advertising, and that unless otherwise noted each such partner is an independent controller of the data. It publishes a partner list and also permits disclosure of personal information in business transfers, including bankruptcy.

legal.applovin.com ↗

[2026-07-22] · SHARING

AppLovin's U.S. Multistate Privacy Notice states it does not sell personal information in direct exchange for money, but acknowledges that passing device data in bid requests to its demand-side partners constitutes 'sharing' and may be a 'sale' under the CCPA and other state privacy laws; residents of covered states may opt out of such sales/sharing.

legal.applovin.com ↗

[2026-02-19] · TRACK RECORD

sec.gov ↗

[2026-05-22] · TRACK RECORD

In May 2026, Dutch foundation The Privacy Collective, backed by Amnesty International Netherlands, filed a class action alleging AppLovin unlawfully collected and traded personal data of millions of Dutch users — including an estimated 1.5 million children — via tracking software in popular apps such as CapCut, Vinted, and Subway Surfers, in alleged violation of the GDPR. These are untested allegations in pending litigation.

jurist.org ↗

[2026-02-19] · TRACKING TECH

AppLovin's FY2025 10-K states it relies in part on Apple's Identifier for Advertisers (IDFA) for data that helps its advertising solutions market and monetize mobile apps, and that it changed its data collection practices in light of Apple's IDFA and transparency changes.

sec.gov ↗

[2026-07-21] · TRACKING TECH

AppLovin's privacy policy states that data is collected automatically across mobile apps and devices over time, received from third parties such as mobile measurement partners, and combined with information AppLovin derives through analytical techniques; for e-commerce, collection occurs through its SDK or pixel on merchant properties or via third-party APIs.

legal.applovin.com ↗

LAST REVIEWED 2026-08-27 · METHODOLOGY v1.7