Adjust GmbH: AppLovin’s measurement company

attributedThe Privacy Collective (TPC) sues on behalf of Dutch residents who since May 25, 2018 have used Android or iOS apps containing AppLovin or Adjust software development kits, a group it puts at no fewer than 8.5 million people, including about 1.5 million minors. It alleges that processing their data through the SDKs and real-time bidding auctions lacks a legal basis, transparency and protection for children, in breach of the GDPR, including its information duties (Articles 12 to 14) and the ban on processing special categories of data such as health, religion and sexual orientation (Article 9), and of Article 11.7a of the Dutch Telecommunications Act. TPC describes Adjust as a German group company of AppLovin providing measurement and attribution services and alleges that the two jointly determine the purposes and means of the processing. It seeks a declaration of joint and several liability, orders stopping the SDK practices and deleting data, penalty payments of EUR 1,000,000 per violation plus EUR 250,000 a day capped at 4% of the defendants' worldwide annual turnover, and compensation for non-material and material damage; the press reported claims of EUR 1,500 per child and EUR 500 per adult, amounts not stated in the register extract. ^{1 2}

qualification

These are the claimant's allegations; Adjust's place in the group is separately documented in AppLovin's subsidiary lists.

outcome

The case was due for its first docket date on August 26, 2026. No ruling on the merits is in the record as of mid-October 2026.

attributedCiting unnamed former Adjust executives, Fuzzy Panda Research alleged that after buying Adjust, AppLovin whitelisted itself in Adjust's fraud detection and fired a majority of Adjust's anti-fraud team. ³

qualification

Based on unnamed sources. No regulator or court has ruled on these allegations in the record.

response

AppLovin said Adjust and MAX operations are "entirely independent and transparent, with no conflicts or house bias".

attributedShort seller Fuzzy Panda Research wrote in February 2025 that a class action filed in California in August 2024 (Santa Clara County Superior Court, No. 24CV434574), which AppLovin had not disclosed, accuses the company of using the Adjust SDK to collect a "wealth of information", including precise location, IP addresses and device identifiers, and to track users without their consent. ³

qualification

The complaint itself was not retrieved; AppLovin's filings in the record do not name this case, and its course is not known.

attributedCount 16 of the Justice Department's complaint, against the same defendants, alleges that on April 22, 2021 KKR Americas Fund XII L.P. indirectly acquired Adjust, through AppLovin's purchase, for between $376 million and $919 million without a prior premerger filing, again corrected on December 3, 2021. ⁴

qualification

These are allegations in a government complaint; the defendants consented to a proposed judgment without any admission or adjudication of fact or law, and AppLovin is not a defendant.

response

According to the Justice Department, KKR told the FTC in December 2021 that the failures to file were inadvertent and arose from an unusual and unanticipated set of circumstances related to the timing of a complicated restructuring transaction, and made corrective filings for both transactions.

outcome

A proposed final judgment filed on August 26, 2026 requires KKR & Co. GP LLC to pay a $250 million civil penalty within 30 days of its entry; the Federal Register notice of September 4, 2026 opened a 60-day comment period, so the judgment had not been entered in the record.