Adapter Group, Inc. Privacy Policy
Effective Date: May 18, 2026
At Adapter Group, Inc. ("Adapter," "we," "us," or "our"), our mission is to empower you with useful knowledge and delightful outcomes. To do so, we need personal information from you. We don't take this responsibility lightly. Earned trust, privacy, and transparency are pillars of the Adapter experience and core to our mission and purpose. We aim to lead with an individual-centric philosophy with robust privacy measures, clear consent processes, and open communication about how your information is collected, used, disclosed and stored. We will always strive to keep you informed and in control of your information, and empower you to manage your Adapter configuration preferences at every step.
We are committed to protecting your personal information from third parties. It is and will remain our policy to not sell your personal information to third parties and, unless we receive your consent, to limit and restrict any sharing of your personal information with third parties for any purpose other than as reasonably necessary to enable and provide your Adapter experience.
This Privacy Policy ("Privacy Policy") applies to and governs the collection, processing and use of your personal information by Adapter during our service offering available at our affiliated Adapter.com website (the “Service”). The Service is subject to our Terms of Service. We have tried to make this Privacy Policy as straightforward as possible, but we realize it contains a lot of information. If you still have any questions after you review it, please reach out to us at support@adapter.com. If you do not agree with this Privacy Policy, please do not access or use our service.
1. UPDATES TO THIS PRIVACY POLICY
This Privacy Policy is current as of the Effective Date above. We may update this Privacy Policy from time to time to reflect changes in the Service, applicable law, regulatory guidance, or data processing practices. For non-material changes, we will provide reasonable advance notice before they become effective, which may include posting an updated version on the Service, sending notice to the email address associated with your account, or providing another notice required by applicable law. For material changes, particularly those affecting how we collect, use, or share sensitive personal information or AI-generated inferences, we will obtain your affirmative consent before such changes take effect if required by law. We will present a clear in-app or email prompt requiring you to acknowledge and accept material changes before continued use of the Service. If we do make changes, they will be reflected in the updated Privacy Policy on our website. Where required by applicable law, we will not use your personal information we collected previously for materially different, unrelated, or incompatible purposes without first providing any required notice and obtaining any required consent.
The date the Privacy Policy was last updated will always be reflected at the top of this page. For non-material changes, your continued use of the Service after the effective date of any updated Privacy Policy constitutes your acceptance of those updated terms. For material changes, your affirmative consent may be required as described above.
2. PERSONAL INFORMATION WE COLLECT
We collect personal information that you provide to us. We also collect personal information automatically when you use the Service, and personal information from third-party sources through which you provide your consent to share your information or integrate with us, as described below. We will make inferences about you based on the personal information you provide to us to ensure our Service is most aligned to serving you well. We do this for the sole purpose of delivering and optimizing your Adapter experience. We collect, use, retain and disclose personal information only to the extent reasonably necessary and proportionate to provide and maintain the Service, develop and improve the Service, protect the rights and safety of users and others, comply with legal obligations, and carry out other disclosed purposes permitted by law.
a. Personal Information You Provide to Us
We may collect personal information that you provide to us. We do not sell personal information, including sensitive personal information. Specifically:
Account Information. We may collect personal information in connection with the creation or administration of your Adapter account. This personal information may include, but is not limited to, your name, email address, and other information you store with your account.
Google User Data. When you connect your Google account to our Service, we may access your Google user data that you affirmatively authorize through the Google consent flow ("Google User Data"). We will access, use, store, transfer, and otherwise process your Google User Data only for the specific functionality requested by you, in accordance with the Google API Services User Data Policy, including its Limited Use requirements, and as otherwise disclosed in this Privacy Policy. Specifically: (i) we access Google User Data only to the extent necessary to provide the Service; (ii) we do not use Google User Data for advertising purposes; (iii) we do not allow humans to read your Google User Data unless you have given us express permission to do so, it is necessary for security purposes, or we are required to do so by law; and (iv) we do not transfer Google User Data to third parties except as necessary to provide the Service, as required by law, or with your consent.
You have control over what Google User Data you permit us to access: you can set the time frame and topic for the Google User Data you are comfortable permitting Adapter to access. For example, Gmail permissions include access to your inbox and emails. Google Calendar permissions include access to your calendar, calendar events, calendar lists, and calendar settings. You may voluntarily give us certain information when scheduling and setting up a calendar event, including your name, email address, and phone number; email addresses of other people and/or invitees; the subject of the meeting; and any other information a user typically provides when scheduling. You may revoke our access at any time through your Google account settings or within the Service. We access only the minimum Google User Data necessary to provide the Service, consistent with our data minimization obligations. Google User Data is retained only for as long as necessary to provide the Service and is deleted upon account deletion, subject to any limited retention required by law or for documented security, fraud prevention, or dispute-resolution purposes. Please see Section 4(d) below for additional information regarding our use of Google API Services.
Inferences about Your Interests and Preferences. Adapter's technology generates inferences about your preferences and interests when processing your personal information. For example, if Adapter selects an aisle seat on your favorite airline departing after your typical morning breakfast timer, Adapter will have inferred that you prefer that airline, aisle seats, and flights that aren't too early. Adapter aggregates all such inferences in our proprietary database called the Adapter Knowledge Base. We restrict access to the Adapter Knowledge Base to only authorized Adapter personnel and service providers, and only Adapter personnel's and authorized service providers' securely developed systems can interact with the Adapter Knowledge Base. Please see Section 11 (Automated Decision-Making and AI Inferences) for more information about how these inferences are generated and your rights with respect to them.
Sensitive Personal Information. Depending on how you interact with the Service, in the course of providing the Service, we may collect or infer information that constitutes “sensitive personal information” or a similar term under applicable law, including precise geolocation data, the contents of communications made available through connected email or calendar services, account credentials or authentication information needed to access integrated services, information revealing health-related appointments or interests if you choose to connect such information, and personal Information used to create detailed profiles or inferences about your preferences, characteristics, behavior, or activities. We use sensitive personal information only for the purposes described in this Privacy Policy and do not use or disclose it for purposes beyond what is reasonably necessary to provide the Service. Where required by applicable law, we obtain your consent before collecting or processing sensitive personal information for purposes that are not necessary to provide the Service as you have requested, and you may withdraw that consent as provided in this Privacy Policy. You may have the right to further limit our use of your sensitive personal information as described in Section 6 (Your Privacy Choices) below.
Your Communications with Us. We, and our service providers, will collect the information you choose to communicate to us, such as through email and other permitted mediums, if any, that are integrated with the services.
Surveys. We will likely contact you to participate in customer feedback surveys. If you decide to participate, we will collect personal information from you in connection with the survey.
Feedback. We will ask to collect feedback or suggestions from you to help us test our Service. If you encounter any issues or faults with our Service, we would love to hear about them; our primary reason for running any services or beta programs is to iron out issues before making our services widely available.
Interactive Features. We and others, including third-party websites, applications, services, products and technologies (each a "Third-Party Service") that interact, share information with, access and/or use information directly or on your behalf, in connection with our Service, may collect personal information that you submit or make available through our interactive features. If you choose to connect your Adapter account to a Third-Party Service, we may receive or be granted access to information from such Third-Party Service, including your personal information. Further, you may publicly share and interact with others who are not participating in the Service to schedule a calendar invitation generated by us. Note that any information you provide using the public sharing features of the Service will be considered "public."
Business Development and Strategic Partnerships. We may collect personal information from you to assess and pursue potential business opportunities, but we will first notify you and ask for your consent before we do so.
b. Personal Information Collected Automatically
We collect personal information automatically when you use the Service.
Device Information. We collect personal information about your device, such as your Internet protocol (IP) address, settings, cookie identifiers, other unique identifiers, browser or device information, Internet service provider, and location information (including, as applicable, approximate location derived from IP address and precise geo-location information).
Usage Information. We collect personal information about your use of the Service, such as the pages that you visit, items that you search for, the types of content you interact with, information about the links you click, the frequency and duration of your activities, and other information about how you use the Service.
Cookie Notice (and Other Technologies). We use cookies, pixel tags, and other technologies ("Technologies") to automatically collect personal information through your use of the Service. Cookies are small text files stored in device browsers. As of today, we are not utilizing any third-party cookies. It is our intent to strictly limit the number of third-party technology providers to the absolute minimum required. See "Your Privacy Choices" below to understand your choices regarding these Technologies.
c. Personal Information Collected from Third Parties
We collect personal information about you from third parties, provided you consent to us connecting to or integrating with them. For example, if you access the Service using a Third-Party Service, we will collect personal information about you from that Third-Party Service that you have made available via your privacy settings. In addition, as noted above, users of the Service will upload or otherwise provide personal information about others who are not participating in the Service but who through other means will (outside of Adapter) have consented or agreed to share their information with you and the technology providers you use, by sending information to your email inbox, virtual calendar, or to your mobile device. We understand how important your information is. We too are customers of Adapter services as individuals. We will limit our use of your personal information as set out here.
3. HOW WE USE PERSONAL INFORMATION
a. Provide the Service
We use personal information to provide the Service, such as:
Managing your information;
Providing access to certain areas, functionalities, and features of the Service;
Answering requests for support;
Communicating with you;
Sharing personal information with our limited and approved third-party service providers as needed to provide the Service.
b. Administrative Purposes
We use personal information for various administrative purposes, such as:
Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
Carrying out analytics;
Measuring interest and engagement;
Improving, upgrading, or enhancing the Service;
Developing new features;
Creating de-identified and/or aggregated information;
Ensuring internal quality control and safety;
Debugging to identify and repair errors with the Service;
Auditing relating to interactions, transactions, and other compliance activities;
Enforcing our agreements and policies;
Carrying out activities that are required to comply with our legal obligations.
c. Automated Processing, Profiling and AI-Enabled Features
We may use personal information, including information from connected third-party services, to generate recommendations, predictions, summaries, preferences, rankings, and other outputs through automated processing, machine learning, or similar AI-enabled functionality. This processing may include creating and storing inferences about your interests, habits, scheduling preferences, travel preferences, communication patterns, or similar characteristics in the “Adapter Knowledge Base.”
· How it works: Our AI systems analyze patterns in your personal information — including your calendar data, email metadata, and usage behavior to build a profile of your preferences. This profile is used to automate actions and recommendations on your behalf within the Service. These inferences are stored in the Adapter Knowledge Base and are used to provide, personalize, secure, maintain, and improve your Adapter experience. For example, we may infer your preferred airline, seating preferences, scheduling habits, and other behavioral patterns based on your Google User Data and usage of the Service.
· Significance: These inferences may influence the actions Adapter takes on your behalf, such as booking travel, scheduling meetings, or making recommendations. While these decisions are designed to serve your interests, they are based on automated processing of your personal information.
· Your rights regarding automated processing: We do not use personal information for solely automated decisions producing legal or similarly significant effects unless permitted by applicable law and accompanied by any required notice, consent, and consumer rights.
o Where required by law, you may opt out of profiling in furtherance of decisions that produce legal or similarly significant effects. You have the right to opt out of the use of your personal information for profiling and automated decision-making. See Section 6 above.
o You have the right to access the inferences we have made about you. You may request a copy of your Adapter Knowledge Base profile by contacting us at support@adapter.com.
o You have the right to correct inaccurate inferences. If you believe an inference is incorrect, you may request correction through your account settings or by contacting us.
o You have the right to delete inferences about you as part of an account deletion request.
We do not use automated decision-making to make decisions that produce legal effects or similarly significant effects on you without human oversight, except as necessary to provide the core functionality of the Service.
We will endeavor to describe the categories of personal information used in these AI-enabled features, the types of outputs generated, and the role of automated processing in user-facing functionality in a clear and meaningful way. To the extent required by applicable law, we will also provide disclosures regarding the sources of personal data or datasets used for AI-enabled features and how those datasets are used to advance the intended purposes of such features.
d. Marketing
We may use personal information to send you certain communications in connection with your use of our Service, including marketing and other content, only as permitted by law. You may opt out of promotional emails by using the unsubscribe link in those messages or by contacting us as described below. We do not share personal information for cross-context behavioral advertising unless and until such activity is clearly disclosed and you are provided any rights required under applicable law. Opting out of promotional messages will not affect transactional, service-related, security, legal, or other non-promotional communications. If you have any questions about our marketing practices, you may contact us at any time as set forth in "Contact Us" below.
e. With Your Consent
If we seek to use your personal information for other purposes not listed in this Privacy Policy, we will clearly disclose our intentions to you in advance, prior to the time you provide personal information, and we will first obtain your consent.
4. HOW WE DISCLOSE PERSONAL INFORMATION
We may disclose personal information only as described in this Privacy Policy, for purposes that are reasonably necessary and proportionate to the disclosed purposes, and subject to contractual, technical, and organizational safeguards appropriate to the nature of the information and the role of the recipient. We may disclose a small subset of your personal information to a limited number of third parties that we have vetted and approved for critical and necessary business purposes related to the delivery of the Service, or to protect us or others.
a. Disclosures to Provide the Service
We may disclose a small subset of the personal information we collect from you to the categories of third parties described below. We are responsible to you, our customer. We are committed to work only with vetted and specifically chosen third-party business partners who we believe share an aligned common interest in empowering you through our collective collaboration.
Service Providers. We may disclose personal information to third-party service providers that assist us with the provision of the Service. This may include, but is not limited to, service providers that provide us with hosting, account creation and authentication, customer service, analytics, IT support, and related services. We undertake to enter into appropriate contractual terms with service providers, contractors, and processors, including limits on retaining, using, or disclosing personal information except as needed to perform services on our behalf and as permitted by law. We contractually require all service providers to protect your personal information consistent with this Privacy Policy and applicable law, and to use your personal information only for the purposes for which it was disclosed to them.
Other Users You Share or Interact With. The Service may allow you to share personal information or interact with other customers of the Service, or with others who are not using the Service, but only with others with whom you chose to share your information.
Third-Party Services You Share or Interact With. As noted in "Interactive Features" above, the Service may link to or allow you to interface, interact, share information with, direct us to share information with, access and/or use directly or on your behalf one or more Third-Party Services. Any personal information shared with a Third-Party Service will be subject to the Third-Party Service's privacy policy. We will strive to work only with Third-Party Services whose interests in protecting your personal information are aligned with our values, but we cannot be responsible for the processing of personal information by Third-Party Services.
Business Partners. We may share a small subset of personal information with approved business partners to provide you with a product or service (including a Third-Party Service) that you have requested. Once your personal information is shared with our business partner, it may also be subject to our business partner's privacy policy. We are not responsible for the processing of personal information by our business partners.
b. Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others' rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity. We will endeavor to always put forth to the best of our knowledge all reasonable protections afforded to you, our customer, in the jurisdiction(s) where matters such as these may be brought.
c. Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed, sold, or transferred as part of such a transaction for the continued operation of the Service.
d. International Data Transfers and Restrictions
Our application and database servers are located in the United States. Personal information may be processed and stored in the United States and other jurisdictions where we or our service providers operate, subject to appropriate safeguards and as permitted by law. If we offer the Service to users outside the United States, we will take steps required by applicable law for cross-border transfers of personal information. We do not knowingly transfer bulk sensitive personal data to foreign countries or entities subject to restrictions under applicable U.S. law, including Executive Order 14117 and implementing regulations (28 CFR Part 202). We contractually require our service providers to comply with applicable restrictions on cross-border data transfers, including prohibitions on transferring your personal information to countries of concern as designated under applicable U.S. law.
5. DATA RETENTION
We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including to provide the Service, maintain appropriate business and financial records, comply with legal obligations, resolve disputes, and enforce agreements. Retention periods vary depending on the category of data and the purpose for which it was collected. For example, account information may be retained for the life of the account and a reasonable period thereafter; usage logs and device data may be retained for security, debugging, analytics, and fraud prevention; communications and support records may be retained for follow-up and quality assurance; and inferences or preference profiles stored in the Adapter Knowledge Base may be retained only while reasonably necessary for the relevant Service functionality, unless longer retention is required or permitted by law.
When personal information is no longer reasonably necessary for disclosed purposes, we will delete, deidentify, or aggregate it, unless retention is required or permitted by law.
6. YOUR PRIVACY CHOICES
The privacy choices you may have about your personal information are described below.
Email Communications. If you receive an unwanted email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails. We may also send you certain non-promotional communications regarding us and the Service, and you will not be able to opt out of those communications (e.g., communications regarding the Service or updates to this Privacy Policy).
"Do Not Track." Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. DNT is associated with individual activity tracking across multiple service providers. Adapter does not respond to DNT signals. While Adapter exists to understand your individual activity to provide our services, including our Service, we do not participate in the cross-site tracking enablement of other third parties such as advertising networks, advertising cookies, or similar cross-site tracking mechanisms.
Cookies. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the Service may not work properly. Please note you must separately opt out in each browser and on each device.
Opt-Out of Profiling and Automated Decision-Making. You have the right to opt out of the use of your personal information for profiling in furtherance of decisions that produce legal or similarly significant effects. To exercise this right, please contact us as described in "Contact Us" below or adjust your preferences in your Adapter account settings. Please note that opting out of profiling may limit the functionality of the Service, as personalized inferences are core to the Adapter experience.
Limit Use of Sensitive Personal Information. To the extent we use or disclose sensitive personal information beyond what is necessary to provide the Service, you have the right to direct us to limit such use or disclosure. To exercise this right, please contact us as described in "Contact Us" below.
Account Deletion. You have an option to delete your entire account record, along with all associated personal information. You can do so within your Adapter account settings. However, you won't be able to delete information, including personal information, that we are legally required to maintain.
7. STATE-SPECIFIC PRIVACY RIGHTS
Depending on the state in which you reside, you may have additional rights regarding your personal information. This section describes those rights and how to exercise them. We will not discriminate against you for exercising any of the rights described below.
a. Rights Available to Residents of Certain States
Residents of California, Texas, Florida, Montana, Oregon, New Hampshire, New Jersey, and certain other states with comprehensive consumer privacy laws may have some or all of the following rights:
Right to Know/Access. You have the right to know what personal information we have collected about you, including the categories of personal information, the categories of sources, the purposes for collection, the categories of third parties with whom we share it, and the specific pieces of personal information we hold about you.
Right to Correct. You have the right to request that we correct inaccurate personal information we maintain about you.
Right to Delete. You have the right to request that we delete personal information we have collected from you, subject to certain exceptions (e.g., where we are required to retain the information by law or to complete a transaction).
Right to Data Portability. You have the right to receive a copy of the personal information you have provided to us in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another entity.
Right to Opt Out of Sale or Sharing. We do not sell your personal information to third parties. We do not share your personal information for cross-context behavioral advertising. If this practice changes, we will update this Privacy Policy and provide you with the right to opt out.
Right to Opt Out of Profiling. You have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. See Section 6 above for how to exercise this right.
Right to Non-Discrimination. We will not discriminate against you for exercising any of your privacy rights. We will not deny you goods or services, charge you different prices, or provide you a different level of quality of service because you exercised your privacy rights.
b. How to Submit a Privacy Rights Request
To exercise any of the rights described above, please contact us at support@adapter.com or through your Adapter account settings. We will respond to your request within the timeframe required by applicable law (generally 45 days, with a possible extension of an additional 45 days where reasonably necessary). We may need to verify your identity before processing your request.
c. Authorized Agents
In certain states, you may designate an authorized agent to submit privacy rights requests on your behalf. To use an authorized agent, please contact us at support@adapter.com with written authorization identifying your agent.
8. SECURITY AND INCIDENT RESPONSE
We are committed to working to ensure that our Service is secure and respectful of your privacy by design, and to endeavor to be a market leader. We work hard to prioritize your data privacy and security and protect the personal information that you provide to us. Adapter maintains administrative, technical, and physical safeguards designed to protect Personal Information appropriate to the volume and nature of the Personal Information at issue. No method of transmission over the internet or method of electronic storage is completely secure, and therefore absolute security cannot be guaranteed. We have taken and will continue to take commercially reasonable efforts, which we believe go beyond what is deemed reasonable in the industry, intended to protect the personal information we collect from you. If we become aware of unauthorized access to, acquisition of, or disclosure of personal information, we will investigate the incident and provide any notices required by applicable law to affected individuals, regulators, and others within the timeframes required by applicable law.
9. CHILDREN'S AND TEENS’ INFORMATION
The Service is not directed to or intended for children or minors under the age of 18, and we do not knowingly collect personal information from individuals under 18. Without limiting the generality of the preceding sentence, we comply with the Children's Online Privacy Protection Act ("COPPA") and do not knowingly collect personal information from children under 13 without verifiable parental consent. If we learn that we have collected personal information from a child under 18 without such consent, we will promptly delete that information (i) in accordance with COPPA, with respect to children under 13, and (ii) as required by applicable law if collected from a teen between ages 13 and 17. Where required by applicable law, we will comply with applicable state law requirements and provide additional protections for minors under 18 or other age thresholds established by state law, including with respect to targeted advertising, sale of personal information, profiling, or processing of sensitive personal information. If you are a parent or guardian and believe your child has uploaded personal information to the Service in violation of applicable law, you may contact us as described in "Contact Us" below.
10. THIRD-PARTY WEBSITES/APPLICATIONS
The Service may contain links to other websites/applications and other websites/ applications may reference or link to our Service. These third-party services are not controlled by us, but where we enable integrations with third-party services, we will identify the categories of third parties involved and the categories of personal information disclosed to them as required by this Privacy Policy and applicable law. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.
11. CONTACT US
Adapter has designated a Privacy Officer responsible for overseeing compliance with this Privacy Policy and applicable privacy laws.
If you have any questions about our privacy practices or this Privacy Policy, to exercise your choices as detailed in this Privacy Policy, or to submit a privacy rights request, please contact us at: Privacy Officer. Adapter Group, Inc. privacy@adapter.com.
For general support inquiries unrelated to privacy rights, please contact: support@adapter.com.
If required by applicable law, we will designate and maintain a method for users to submit authenticated privacy rights requests and appeals.