PRIVACY POLICY

This Privacy Policy was last updated on August 22^nd, 2024

This Privacy Policy (“Privacy Policy”, “Policy”) constitutes a legally binding agreement made between you, whether personally or on behalf of an entity (“you”) and ADSPEKT LTD, a limited liability company registered in the United Kingdom under the company number 15152717, having its address at 41 Devonshire Street, Ground Floor, London, United Kingdom, W1G 7AJ, (“we,” “us” or “our”), concerning the regulation of the collection and processing of information, including personal data of individuals and defines the manner in which we process and protect information about individuals who visit or use our website adspekt.com, including any and all subdomains, as well as any other media form, media channel, mobile website, or website related, linked, or otherwise connected thereto (collectively, the “Website”). You agree that by accessing the Website, you have read, understood, and agree to be bound by all of this Privacy Policy. IF YOU DO NOT AGREE WITH ALL OF THIS PRIVACY POLICY, THEN YOU ARE EXPRESSLY PROHIBITED FROM USING THE WEBSITE AND YOU MUST DISCONTINUE USE IMMEDIATELY.

Additional terms, conditions, and any documents that might be posted on our Website from time to time are an integral part of this policy, incorporated by reference. We reserve the right, in our sole discretion, to amend or modify this Privacy Policy at any time and for any reason. Such modifications will be alerted to you through updates of the “Last updated” date of this Privacy Policy and you waive any right to receive specific notice of each such change. It is your responsibility to periodically review this Privacy Policy to stay informed of updates. You will be subject to and will be deemed to have been made aware of and to have accepted, the changes in any revised Policy by your continued use of the Website after the date such revised Policy are posted.

1. General information

1.1. We are the data controller regarding the Personal Data processed within the framework of this Privacy Policy.

1.2. An individual can only use the Website if he/she is aged 18 or over or the age of majority in the country in which he/she resides if that happens to be greater than 18. We do not knowingly collect any information (including Personal Data) or market its services to minors or users under the age of majority.

We will terminate any user’s account upon the discovery that the respective account was created in violation of the provisions of this paragraph.

1.3. We are committed to protecting and respecting the privacy of our users and ensuring their security when using the Website. This Privacy Policy is intended to help the user understand what data and for which purposes the Website collects and how collected data is processed and protected.

1.4. We reserve the right to amend this Privacy Policy; therefore it is recommended that the user of the Website checks the Privacy Policy on a regular basis.

1.5. All the changes to this Privacy Policy are effective as of the “Last updated” date. The user who continues to use the Website after the Last updated date is deemed to accept the changes made to it.

2. Contact us

2.1. You may contact our Data Protection Officer (DPO) by emailing info@adspekt.com.

2.2. By registering on the Website, the user consents to the processing of his/her Personal Data by us in accordance with the provisions set below.

2.3. By registering on the Website, the user gives consent to us to anonymize his/her Personal Data for the purposes of further use in an anonymized form in order to improve the performance of the Website.

3. Collected data

3.1. When using the Website, the user agrees to the processing of the following Personal Data:

3.1.1. Personal Data that the user provides to us:

1. When creating an account, the user provides us with basic details necessary for the Website to work, such as the user’s name, gender, date of birth and location.
2. When completing his/her profile, the user may be able to provide additional information, as well as content, such as pictures and photos.
3. When contacting support service: the information that the user provides during the interaction. We reserve the right to monitor or record interactions between the user and the support service for training purposes and to ensure high quality of service.
4. When participating in user verification procedures: the user’s Personal Data, as requested by the Website for user identification purposes.
5. When participating in surveys or focus groups: insights and evaluation of our services, responses to the questions.

3.1.2. Personal Data collected through the use of the Website:

When the user is using our Website, we may collect data regarding the device(s) the user uses to access the Website (such as his/her IP address, device identifier (including unique advertising device identifiers, for example, Google Advertiser ID and IDFA), technical and statistical data (including data about the Internet connection, cellular service provider and application usage data) and location data.

3.2. By providing Personal Data to us, the user warrants that such data is true, accurate and up to date.

4. Use of user’s personal data

4.1. We collect, process and use the Personal Data of users of the Website based on the following grounds:

1. when such processing is performed in order to fulfil the contract between us and the user;
2. based on our legitimate interest;
3. upon explicit prior consent from the user.

4.2. We collect and process the Personal Data of the Website’s users in order to maintain the functionality of the Website and to ensure compliance with legal and business-related requirements.

The user’s Personal Data is processed for the following purposes:

4.2.1. When processing of personal data is related to the fulfilment of the contract between us and the user:

1. to set up, operate and manage the user’s account;
2. to proceed and respond to the requests and enquiries received from the user;
3. for administrative purposes, such as service messages (including but not limited to the Website’s maintenance messages, updates to the Privacy Policy and Terms and conditions).

4.3.2. Under our legitimate interests:

1. if applicable, to connect the user's account to a social network;
2. for user verification purposes, conducted in relation to ongoing or alleged misbehaviour, performed by the user of the Website, in order to block accounts as part of the anti-spam procedures, to investigate possible fraud;
3. to evaluate the effectiveness of marketing and to perform market research and training.

4.3.3. Under an explicit consent from the user:

1. to serve the user with targeted advertisements on the Website and to optimize the advertising information according to the user's preferences;
2. to prepare statistics regarding the use of the Website by the user;
3. to identify possible technical malfunctions in the work of the Website, to assist internal research and development and to make improvements to the Website.

5. Duration of the user’s data retention

5.1. We retain the user’s Personal Data for the period of time necessary to carry out relevant activities, specified in section 4 of this Privacy Policy and as permitted by applicable law.

Personal Data, that the user has communicated to us upon registration and subsequently through the use of the Website, will be retained by us as long as the user remains the user of the Website.

5.2. In order to protect the interests of the users of the Website, we retain personal data of the users of the Website for a period of 30 days (retention period) after deletion of the user's account.

5.3. We reserve the right to store the user’s Personal Data for a longer period of time than provided in paragraph 5.1. when it is performed in order to fulfil our legal obligations (including law enforcement requests and dispute resolution), ensure compliance with applicable law or when the relevant Personal Data is stored on the basis of our legitimate interests (including security reasons, prevention of fraud).

6. Disclosure of Personal Data

6.1. We may share the user’s Personal Data with third parties in the following cases:

1. Third-party advertising services.
2. Third-party analytics services.
3. User support services.
4. Providing user’s data by law.

We may disclose the user’s Personal Data when such disclosure is required by law and is reasonably necessary:

• in order to establish, exercise, defend or enforce our legal rights;
• to comply with a legal process such as a court order, subpoena or search warrant, government/law enforcement investigation or other legal requirements;
• to assist in the prevention or detection of crime (subject in each case to applicable law);
• to protect the safety or vital interests of an individual.

6.2. We ensure appropriate contractual control over third parties assisting us in processing the user’s Personal Data, securing that the rights of users of the Website are upheld, their Personal Data is secure and appropriate security and privacy arrangements are in place.

6.3. In the event of a change in our corporate structure, resulting in the transfer of the user’s Personal Data to a third party, all the users of the Website would be notified through a separate notice on the Website. The respective notice would explain the identity of the new data controller and the user’s options regarding the disposal of their Personal Data.

7. User’s rights

7.1. Every user of the Website is a data subject and thus has ultimate rights over his/her Personal Data. The rights of the data subject over his/her Personal Data are as follows:

• Access:

A right to know whether Personal Data concerning the user is being processed by us, right to get information regarding the processing of Personal Data and right to request a copy of Personal Data being processed.

• Rectification:

A right to ask us to correct the user’s Personal Data in a situation when such data available to us or disclosed to third parties is inaccurate or incomplete.

• Erasure:

A right to request ‘to be forgotten’, meaning deletion of the user’s Personal Data from our database so that we are not able to continue processing and storing such data, with exceptions, provided by applicable law.

• Restrict processing:

Right to introduce the restriction regime on the processing of the user’s Personal Data, so that in each case the data may be processed only upon separate consent from the user.

• Data portability:

Right to request for the Personal Data provided to us to be given in a machine-readable format so that it could be transferred to another service provider or to transfer such data directly to a third party designated by the user.

• Object:

Right to object to the processing of his/her Personal Data in a case when the corresponding processing is not performed on the basis of the user’s consent.

• Withdraw consent:

Right to withdraw consent to the processing of his/her Personal Data by us and/or third-party processors of Personal Data. The user should note that withdrawal of consent to the processing of his/her Personal Data will result in the deletion of his/her account on the Website and may result in the termination of his/her use of the Website.

7.2. The abovementioned rights are not absolute. In order to exercise some of the rights, the user should meet certain conditions and requirements, specified by the law.

7.3. For more information regarding his/her rights over Personal Data, the user of the Website should contact info@adspekt.com. In order to exercise his/her rights, the user should submit a request to info@adspekt.com.

7.4. The user of the Website should also be acknowledged of his/her right to complain to a data protection regulator in his/her jurisdiction.

8. Residents of California

8.1. For users who are California residents, the data we may collect falls within the following categories of “personal information,” as defined by the California Consumer Privacy Act (CCPA):

1. Identifiers, such as user’s name;
2. Personal information, as defined in the California customer records law, such as contact (including email);
3. Characteristics of protected classifications under California or federal law (if you choose to provide them), such as age, gender identity, marital status, sexual orientation, race, ancestry, national origin, religion, and medical conditions;
4. Internet or network activity information, such as browsing history and interactions with our websites and apps;
5. Geolocation data, such as mobile device location;
6. Audio, electronic, visual and similar information, such as photos and videos;
7. Non-public education information; and
8. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

8.2. As defined in the California Consumer Privacy Act, we engage in industry-standard advertising business practices that may be considered a sale. We do not knowingly sell personal data related to children under 16 years of age. We participated in selling of the personal data in the last 12 months in the following ways:

1. By allowing advertising networks we partner with to place cookies or other tracking technologies through our sites;
2. By sharing hashed or pseudonymized identifiers with advertising networks to create audiences for use in online advertising.

8.3. For users who are California residents, you also have the following rights (in addition to those listed in section 7 of these Terms) under the California Consumer Privacy Act, and you have the right to be free from unlawful discrimination for exercising your rights under the Act:

1. You have the right to request that we disclose certain information to you and explain how we have collected, used and shared your personal information over the past 12 months.
2. You have the right to request that we delete your personal information that we collected from you, subject to certain exceptions.
3. You have a right to opt out from the sale of your personal data.

To opt out of the sale of your personal data or to exercise any of your rights listed above please send a message to info@adspekt.com.

9. Protection measures

9.1. We work hard to protect its users from unauthorized access to or alteration, disclosure or destruction of their Personal Data. Yet, as with any other technology company, although we take steps to secure users’ information, it cannot be promised or guaranteed that unauthorised access, hacking, data loss, or other breaches will never occur.

We reserve the right to suspend the user’s account without notice if there is a reasonable suspicion of a breach of security or unauthorised access to such an account. If you believe that your account or information is no longer secure, please notify us immediately by sending a message to info@adspekt.com.

9.2. The user should take reasonable steps in order to keep his/her Personal Data safe.

10. Cookies

10.1. In order to guarantee an optimal level of usability and performance and to ensure the relevance of promoted services, we may use cookies and similar technologies in order to track the interaction of users with the Website.

10.2. A cookie is a small file that is stored locally on the user’s technical device as soon as the Website is visited. Cookies function by saving particular sets of data, such as, for example, the user’s language selection. Should the user open the Website again later, a cookie will transmit this data back to the Website. The Website’s cookies don't store personal information like the user’s name or address.

10.3. Types of Cookies

The website uses different types of cookies:

• Session cookies only last while the user is visiting the Website and help us to learn more about the user’s use of the Website during a single session and to help the user use the Website more efficiently.

• Persistent cookies have a longer lifespan and aren't automatically deleted when the user closes the Website. These cookies are primarily used to help the user to sign in to the account at the Website again quickly, for security and analytical purposes. We do not use any information whilst the user is logged off the Website.
• We use first-party cookies that is when the cookies are placed on the user’s device directly by us. For example, first-party cookies are used to adapt the Website to the language preferences and analyze the user experience of the user.
• Third-party cookies are placed on the user’s device by our partners and service providers.

10.4. The user can at any time reset device identifiers by activating the appropriate setting on his/her mobile device. The procedure for managing device identifiers is slightly different for each device. The user should be aware that changes he/she makes to cookie settings may limit the features offered by the Website. In some cases, the user may not be able to use all or part of the Website.

The User can customize the use of cookies on his/her device by changing his/her browser settings as well as his/her device settings (device IDs on his/her cell phone) to block cookies on the device.

10.5. Below is information about how we use the users’ cookies on the Website:

• Necessary cookies:

These cookies are strictly necessary to provide the user Website’s access and functionality.

• Authentication cookies:

These persistent cookies help the Website to identify the users so that the user can log into the Website account automatically.

• Analytics cookies:

These cookies help us to understand how the Website is being used, and help us customize and improve the Website.

• Interest-based advertising tools:

These cookies are used to make advertising messages more relevant to the user. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, selecting advertisements that are based on the user’s interests and measuring the number of ads displayed and their performance, such as how many people clicked on a given ad.

11. Cross-border data transfer

11.1. Disclosure of our users’ Personal Data, as provided in section 6 of these Terms of Use sometimes involves cross-border data transfers to other jurisdictions. We use standard contract clauses approved by the European Commission or other suitable safeguards to permit data transfers from the EEA to other countries. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of user’s Personal Data.